Surplus land title continues until statutory vesting notification, so estate duty valuation includes the land itself, not compensation alone.

Under the land reforms scheme, surplus land was not divested from the owner merely because it exceeded the ceiling limit. Title continued until the statutory vesting notification was issued, after the prescribed steps for return, draft statement, final statement, and compensation were completed. On that footing, the deceased remained owner of the surplus land on the date of death, so estate duty valuation had to treat the land itself as the relevant asset and not confine the estate to the compensation receivable.

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Issues: Whether, for estate duty purposes, the deceased had ceased to be the owner of land in excess of the ceiling limit under the land reforms law on the date of death, so that only the compensation receivable could be taken as the asset value.

Analysis: The ceiling law provided that mere excess holding was not enough to divest title. The statutory scheme showed that the land would vest in the Government only upon publication of the notification under the vesting provision, and until that stage the holder continued to retain ownership. The provisions dealing with return, draft statement, final statement, and compensation demonstrated that vesting and extinction of title occurred only after the prescribed statutory steps were completed. The earlier single-judge view was displaced by the later Division Bench ruling, which held that the ceiling provision by itself did not extinguish ownership and that vesting followed only the statutory notification.

Conclusion: The deceased continued to be the owner of the surplus land on the date of death, and the Tribunal was wrong in treating only the compensation receivable as the relevant asset value.

Ratio Decidendi: Under the land reforms scheme, title to surplus land is not extinguished by the mere operation of the ceiling provision; ownership continues until statutory vesting occurs by notification, and asset valuation must proceed on that footing.

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