Section 55A valuation reference not mandatory when contemporaneous market-rate evidence is undisputed and sufficient.

Section 55A of the Income-tax Act was held not to require an Assessing Officer to seek a Valuation Officer's reference where contemporaneous documentary material already fixed the relevant market rate and the assessee did not seriously dispute it. The assessee's registered valuer's estimate was therefore not enough to trigger the statutory power, because independent valuation is needed only when the officer has reason to doubt the value or needs assistance on the facts. The refusal to make a reference was upheld, and the issue was decided against the assessee and in favour of the Revenue.

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Issues: Whether the Assessing Officer was bound to make a reference to the Valuation Officer under Section 55A of the Income-tax Act for determining the fair market value of the capital asset.

Analysis: The assessee's valuation was based on a registered valuer's estimate, but the revenue authorities relied on contemporaneous documentary material from UPSIDC showing the rate of the plot as on 1 April 1981. Since the assessee did not dispute that material rate and there was no real dispute requiring independent valuation, the statutory power under Section 55A was not attracted. A reference to the Valuation Officer is warranted only where the Assessing Officer has reason to doubt or otherwise needs assistance in determining fair market value on the relevant facts.

Conclusion: The question was answered against the assessee and in favour of the Revenue; the refusal to refer the matter to the Valuation Officer was upheld.

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