Acquisition land valuation must follow the presently ascertainable award, not arbitrary estimates, until compensation is finally determined.

For wealth-tax valuation, land under acquisition should ordinarily be valued on the basis of the presently ascertainable award where final compensation remains pending, because arbitrary estimates divorced from the Land Acquisition Collector's award and market value cannot be sustained. The assessee's inflated compensation claim and the appellate estimate were rejected as unsafe for valuation, and the agricultural land was to be valued by reference to the existing award until acquisition proceedings attain finality. The valuation of the small non-agricultural parcel inside the village at Rs. 16,000 was found reasonable, supported by surrounding land rates, and was not interfered with.

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Issues: (i) Whether the value of agricultural land in village Nangal Dewat, acquired but pending final determination of compensation, could be fixed on an arbitrary estimate rather than on the amount presently awarded by the Land Acquisition Collector. (ii) Whether the valuation of the assessee's non-agricultural land inside the village at Rs. 16,000 required interference.

Issue (i): Whether the value of agricultural land in village Nangal Dewat, acquired but pending final determination of compensation, could be fixed on an arbitrary estimate rather than on the amount presently awarded by the Land Acquisition Collector.

Analysis: The compensation claimed by the assessee was too exaggerated to be a safe basis for valuation, and the appellate authority's figures had no real nexus either with the market value or with the compensation likely to be finally awarded. For wealth-tax purposes, the only firm and presently ascertainable figure was the amount awarded by the Land Acquisition Collector, subject to revision when the acquisition proceedings attain finality.

Conclusion: The agricultural land was to be valued on the basis of the Land Acquisition Collector's award for the present, and not on the assessee's claim or on the appellate authority's estimate.

Issue (ii): Whether the valuation of the assessee's non-agricultural land inside the village at Rs. 16,000 required interference.

Analysis: The valuation adopted for this small parcel of land was considered reasonable having regard to the rates accepted for the surrounding land and there was no sufficient ground to disturb it.

Conclusion: The valuation of the non-agricultural land was upheld.

Final Conclusion: The department succeeded only in part, as the agricultural land valuation was corrected to align with the existing award while the valuation of the non-agricultural land was maintained.

Ratio Decidendi: For wealth-tax purposes, land under acquisition should ordinarily be valued on the basis of the presently ascertainable award where the final compensation is still sub judice, and arbitrary estimates unconnected with that award or with market value cannot be sustained.

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