Valuation methodology under wealth-tax law is procedural and retrospective, preserving the assessee's self-occupied property valuation option.

Section 7(4) of the Wealth-tax Act was treated as a procedural provision governing valuation methodology and, therefore, as applicable retrospectively to pending and earlier assessments. On that basis, the assessee was permitted to value the self-occupied property at the same figure adopted in the earlier assessment year. The Tribunal relied on earlier Tribunal and High Court views supporting the assessee's valuation option, and the Revenue's challenge to the appellate relief failed.

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Issues: (i) Whether section 7(4) of the Wealth-tax Act was procedural and therefore retrospective in operation; and (ii) whether the assessee was entitled to value the self-occupied property at the same figure as adopted for the earlier assessment year.

Issue (i): Whether section 7(4) of the Wealth-tax Act was procedural and therefore retrospective in operation.

Analysis: The Tribunal followed earlier decisions holding that sub-section (4) of section 7 governed the mode of valuation and was a procedural provision. On that footing, its operation was not confined to assessments arising after its commencement but extended to pending and earlier years.

Conclusion: The provision was held to be procedural and retrospective, in favour of the assessee.

Issue (ii): Whether the assessee was entitled to value the self-occupied property at the same figure as adopted for the earlier assessment year.

Analysis: Once section 7(4) was treated as retrospectively applicable, the assessee's option in relation to valuation of the self-occupied property was accepted on the basis of the consistent view taken in the earlier Tribunal and High Court decisions relied upon in the order.

Conclusion: The assessee was entitled to the valuation benefit, in favour of the assessee.

Final Conclusion: The Revenue's challenge to the appellate order failed, and the valuation relief granted to the assessee was sustained.

Ratio Decidendi: A provision governing valuation methodology is procedural in nature and, unless the statute indicates otherwise, applies retrospectively to pending and earlier assessments.

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