Ceiling-law restricted land valuation must reflect non-vesting and transfer limits, not just statutory compensation.

Vacant land covered by the Urban Land (Ceiling and Regulation) Act, 1976 could not be valued solely at the compensation payable under section 11 where there was no proof that the excess land had been determined, notified under section 10(1), or vested in the State under section 10(3). The statutory compensation right arises only after completion of the acquisition and vesting process. Until then, the owner retains title, subject to ceiling-law restrictions and transfer impediments that must be reflected in valuation. The section 11 compensation figure was therefore not the true fair market value, and revaluation of the land with due regard to those restrictions was upheld.

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Issues: Whether vacant land affected by the Urban Land (Ceiling and Regulation) Act, 1976 had to be valued merely at the compensation payable under section 11 of that Act, or whether the valuation had to reflect the absence of proof of acquisition, vesting, and the restrictions affecting transferability of the land.

Analysis: The land was subject to the ceiling law, and the assessee had filed a statement of excess vacant land, but there was no evidence that the competent authority had worked out the excess land or published the notification required under section 10(1), or that the land had vested in the State Government under section 10(3). The right to compensation under section 11 arises only after the statutory acquisition process is completed and vesting takes place. Until then, the assessee remains the owner, though with legal restrictions and practical impediments that must be taken into account in valuation. The compensation figure under section 11 could not, therefore, be treated as the true fair market value. The direction to revalue the land with due regard to the ceiling law restrictions was held to be proper.

Conclusion: The valuation could not be restricted to the section 11 compensation amount, and the remand direction was upheld.

Final Conclusion: The appeals failed because the assessee was not shown to be entitled, on the relevant valuation dates, to value the land solely on the basis of compensation payable under the ceiling law.

Ratio Decidendi: Where excess vacant land has not been shown to have vested in the Government under the statutory acquisition process, its valuation for wealth-tax purposes must reflect the restrictions imposed by the ceiling law, and cannot be equated mechanically with the compensation payable under the land ceiling statute.

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