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Issues: Whether, for wealth-tax purposes, the value of compensation receivable on compulsory acquisition had to be taken at the amount originally fixed by the Land Acquisition Officer or at the enhanced amount finally determined by the Civil and Sessions Judge.
Analysis: The value of acquired property is determined with reference to the notification under Section 4 of the Land Acquisition Act and, under Section 11, the compensation represents the value of the acquired asset. On the relevant valuation date, the amount payable was governed by the award of the Land Acquisition Officer; but when the return was filed, the Civil and Sessions Judge's enhanced award had already come into existence. That order superseded the earlier award, and the original determination merged in the later adjudication, making the enhanced compensation the legally recognised and enforceable amount.
Conclusion: The valuation for wealth-tax had to be taken at the compensation eventually fixed by the Civil and Sessions Judge, against the assessee and in favour of the Revenue.
Final Conclusion: The reference was answered by holding that the enhanced compensation fixed in the judicial award constituted the relevant value of the asset for wealth-tax purposes.
Ratio Decidendi: Where compensation for acquired property is finally enhanced before the return is filed, the legally operative compensation amount for wealth-tax is the amount determined by the final award, since the earlier award merges in the later adjudication.
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