Wealth-tax valuation must follow the award on the valuation date; later compensation enhancement cannot justify rectification.

For wealth-tax purposes, the right to receive compensation must be valued on the valuation date by reference to the award or order then in force. A later enhancement of compensation does not justify rectification of the assessment to substitute the eventual higher amount, because no provision in the Wealth-tax Act authorises such post facto correction merely on account of subsequent enhancement. The Delhi HC therefore accepted the Tribunal's view that the rectification direction was wrongly deleted and answered the reference against the Revenue, leaving the assessee's position undisturbed.

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Issues: Whether the Tribunal was correct in deleting the direction permitting rectification of the wealth-tax assessment if compensation was enhanced later.

Analysis: The valuation of the right to receive compensation had to be made with reference to the award or order already passed on the valuation date. A later enhancement of compensation did not furnish any basis for rectifying the assessment merely to substitute the amount eventually payable. The issue was covered by existing precedent, and no provision in the Wealth-tax Act authorized such a post facto rectification on account of subsequent enhancement.

Conclusion: The Tribunal was correct in law in deleting the rectification direction, and the question was answered against the Revenue.

Final Conclusion: The reference was declined and the petition stood dismissed, leaving the assessee's position undisturbed.

Ratio Decidendi: For wealth-tax purposes, the right to receive compensation must be valued as on the valuation date by reference to the award or order then in force, and the assessment cannot be rectified merely because compensation is enhanced later.

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