Reliable valuation evidence governs land pricing where a departmental report is inconsistent and unsupported by the record.

An appellate authority may reject a departmental valuation report where it rests on inconsistent assumptions and does not address defects noted in earlier appellate findings or other valuation material. On the available evidence, the appellate valuation of seven land plots at Rs. 8.74 lakhs as on 31 March 1976 was treated as reasonable, particularly in view of rising real estate values. The rejection of the Revenue's valuation report and adoption of the assessee-favourable valuation were upheld.

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Issues: Whether the appellate authority was justified in rejecting the departmental valuation report and in valuing the seven plots of land at Rs. 8.74 lakhs as on 31 March 1976.

Analysis: The valuation report relied upon by the Revenue was found unreliable because it proceeded on inconsistent assumptions and did not address the infirmities noted in the earlier appellate order and the other valuation material on record. The available reports did not furnish dependable guidance for the valuation date in question. On the remaining material, the appellate valuation of the plots at Rs. 8.74 lakhs was considered reasonable in light of the rise in real estate values.

Conclusion: The rejection of the departmental valuation report and the adoption of the valuation at Rs. 8.74 lakhs were upheld in favour of the assessee.

Ratio Decidendi: An appellate authority may disregard an unreliable valuation report and adopt a reasonable valuation based on the material available on record.

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