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Issues: Whether the appropriate authority's order under Chapter XX-C of the Income-tax Act, 1961 was vitiated for ignoring relevant comparable sale instances and special circumstances affecting the property's value.
Analysis: The valuation exercise was required to take into account all material features affecting market value, including the peculiar circumstances of the proposed vendors, the comparative characteristics of the relied-upon properties, the extent of open sides, parking space, construction quality, and the authorised nature of the terrace servant quarters. The authority compared the subject property with properties that were not truly comparable and also ignored a sale instance relied upon by the purchaser. Since these relevant factors bearing on valuation were left out of consideration, the order could not be sustained.
Conclusion: The order of the appropriate authority was invalid and the challenge to it succeeded.
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