Compensation included in valuation as Court accepts Tribunal's view; limitation and penalty issues left for review.

Compensation received by an assessee was treated as includible in the valuation exercise, with the Court accepting the Tribunal's view on the main issue. The question of extended limitation and consequential penalty was not decided on merits and was instead relegated to review before the Tribunal. The operative effect was that the compensation amount remained part of valuation for the purpose under consideration.

---

---

Issues: Whether the amount of compensation received by the assessee could be included for the purpose of valuation.

Analysis: The Court agreed with the Tribunal on the main issue and accepted the view that the compensation received formed part of the valuation exercise. The question relating to invocation of the extended period of limitation and consequential penalty was not decided on merits and was relegated to review before the Tribunal.

Conclusion: The inclusion of the compensation amount in valuation was upheld.

---