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Issues: Determination of the fair market value of the land as on 1 April 1981 for computation of capital gains.
Analysis: The valuation based on the registered valuer's report was rejected because it proceeded on an unsound commercial-development assumption and did not rest on a reliable factual foundation for valuation of an industrial plot. The valuation adopted by the first appellate authority was upheld because it was based on a combination of material such as nearby sale instances, recognised valuation references, the developed nature of the area, and a reasonable annual rate of appreciation. The Tribunal held that valuation of immovable property is not an exact science and that, in the absence of identical comparable instances, a reasoned estimate based on available material is permissible.
Conclusion: The fair market value fixed by the first appellate authority was sustained and the competing challenges of both parties failed.
Final Conclusion: The valuation adopted for computing capital gains was left undisturbed, and both cross-appeals were dismissed.
Ratio Decidendi: Where exact comparable sales are unavailable, fair market value may be determined on the basis of a reasoned estimate drawn from relevant surrounding material, and a valuation report based on speculative assumptions may be rejected if it lacks a reliable factual foundation.
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