Wealth tax on motor accident compensation depends on finality of the claim, not the tribunal award date.

Compensation awarded by the Motor Accident Claims Tribunal was not an enforceable asset on the date of the award where the State immediately challenged it in the High Court. The amount became includible in the assessee's net wealth only when the claim attained finality after the High Court's decision and expiry of the further appeal period, because only then did the right to receive the compensation crystallise. An interim deposit directed by the High Court did not create an unconditional or absolute ownership interest. The interest component followed the same treatment and was taxable in the year the compensation claim crystallised.

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Issues: Whether the compensation awarded to the assessee by the Motor Accident Claims Tribunal, together with interest, constituted taxable wealth in the relevant assessment years, and when such amount became includible in the assessee's net wealth.

Analysis: The award of the Motor Accident Claims Tribunal was not final when made, as the State immediately challenged it before the High Court seeking reversal of the award in its entirety. On those facts, the assessee did not acquire an enforceable asset merely on the date of the Tribunal's award. The amount became part of the assessee's wealth only when the claim attained finality after the High Court's decision and the expiry of the further period for appeal. The interim deposit ordered by the High Court was not an unconditional or absolute benefit and did not make the full compensation amount presently owned by the assessee. The interest component, once the compensation became finally payable, followed the same tax treatment for the year in which the claim crystallised.

Conclusion: The compensation was not taxable as wealth in the earlier assessment years, but it became includible in the assessee's net wealth for the assessment year 1973-74 together with the interest amount restored by the Tribunal.

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