Wealth-tax property valuation consistency: earlier accepted value governed later years, with only a modest upward revision applied.

For wealth-tax valuation, the accepted value of immovable property for an earlier year was treated as the proper basis for the succeeding two years, reflecting the principle that a previously accepted valuation should ordinarily continue unless material change is shown. The Tribunal also adopted a modest upward revision for the remaining two years rather than the higher departmental valuations, using the earlier accepted figure as the benchmark. The result was partial relief to the assessee, with the property value fixed at a lower uniform level than that proposed by the Wealth-tax Officer.

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Issues: Whether, for the relevant valuation dates in the four assessment years, the value of the assessee's immovable property had to be taken at the same figure accepted for the earlier year, or whether the Wealth-tax Officer's higher valuation should be sustained.

Analysis: The property had been accepted at Rs. 2,12,000 for the earlier year on the basis of an approved valuer's report. The Tribunal treated the departmental instruction that the value adopted for one year should remain effective for the succeeding two years as relevant, and held that the accepted figure had to govern the later years. For the remaining years, the Tribunal considered it fair to adopt a modest increase over the earlier accepted value rather than the higher valuations made by the Wealth-tax Officer.

Conclusion: The assessee succeeded in part. The accepted valuation of Rs. 2,12,000 was directed to be applied for the succeeding two years, and for the other two years the value was fixed at Rs. 2,37,000.

Final Conclusion: The higher valuations made by the Wealth-tax Officer were not fully sustained, and the assessee obtained partial relief by substitution of a lower, uniform value for the property in the relevant years.

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