Valuation of compensation rights for wealth-tax follows settled property principles and no fresh reference was warranted.

The valuation of an assessee's right to receive enhanced compensation for wealth-tax purposes was governed by the settled principle that the right itself is property and must be valued on the relevant valuation date, considering its special nature, marketability, and litigation risk. Applying that principle, the Tribunal was held to have correctly accepted the assessee's valuation based on the Collector's award, as no material justified a different figure. Because the legal position was already settled and no useful purpose would be served by a further reference on the same question, the applications under section 27(3) were dismissed.

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Issues: Whether the applications under section 27(3) of the Wealth-tax Act, 1957 for reference to the High Court were to be allowed on the question of valuation of the assessee's right to receive enhanced compensation for wealth-tax purposes.

Analysis: The valuation principle had already been settled by the Supreme Court in relation to the right to receive compensation under the Land Acquisition Act, namely that the right itself is property and must be valued as on the relevant valuation date, having regard to its peculiar nature, marketability, and the surrounding circumstances, including the risk or hazard of litigation. The Tribunal had correctly appreciated that principle and, in the absence of any material to support a different valuation, accepted the assessee's valuation based on the Collector's award. Since no useful purpose would be served by requiring a reference on the same issue, the applications did not merit interference.

Conclusion: The applications for reference were not allowed and stood dismissed.

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