Yield method valuation of immovable property permits fact-based multiplier and deductions, with separate voluntary disclosure relief allowed.

Immovable property valued on the yield basis requires the multiplier and related deductions to be fixed on the facts, with reasonableness governing the choice of multiplier and allowances for repairs and collection charges. On the facts stated, a 10-times multiplier and deductions for repairs and collection charges were sustained. The voluntary disclosure declaration under the Voluntary Disclosure Act, 1976 created a separate statutory relief, and that deduction could not be denied merely because the valuation was made by the yield method. The separate deduction of Rs. 50,000 was therefore allowable in computing value for the relevant years.

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Issues: (i) Whether the market value of the immovable property was to be determined by applying a multiple of 10 times the net annual value, with allowance for repairs and collection charges; (ii) Whether the assessee was entitled to a separate deduction of Rs. 50,000 on account of the declaration under the Voluntary Disclosure Act, 1976.

Issue (i): Determination of fair market value of immovable property by the yield method depended on the reasonableness of the multiplier and the related deductions. The record showed that the authorities below had used different multipliers, while the evidence and the comparable reasoning supported a moderated multiple. The deduction towards repairs was also considered reasonable, and collection charges were justified on the facts because rent had to be collected through a person and there was tenant litigation.

Conclusion: The market value was to be determined by applying a multiple of 10 times, and the deductions for repairs and collection charges were sustained.

Issue (ii): The declaration made under section 3(1) read with section 13 of the Voluntary Disclosure Act, 1976 created an independent statutory relief. That relief was not absorbed or negated merely because the property valuation was made on the yield method, and it had to be allowed separately in computing the value for the years in question.

Conclusion: The assessee was entitled to the separate deduction of Rs. 50,000 under the Voluntary Disclosure Act, 1976.

Final Conclusion: The valuation dispute was sustained in part on the multiplier and ancillary deductions, while the statutory relief under the voluntary disclosure provisions was allowed separately, resulting in only partial relief to the assessee.

Ratio Decidendi: Where immovable property is valued on the yield basis, the multiplier and allied deductions must be fixed on the facts of the case, and a separate statutory relief cannot be denied merely because the valuation method adopted is independent of that relief.

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