Estate duty valuation of agricultural land upheld where comparable sales supported the appellate rate and gross proceeds were rejected.

For estate duty valuation of cotton-growing land, the appellate authority's rate of Rs. 3,000 per acre was upheld because the Revenue's method wrongly relied on gross sale proceeds instead of net receipts. Comparable sales of adjoining land at about Rs. 1,500 to Rs. 2,000 per acre supported the higher figure adopted on the available material. The departmental challenge to the valuation therefore failed, and the valuation allowed by the Appellate Controller remained undisturbed.

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Issues: Whether the valuation of 8.5 acres of cotton-growing land for estate duty purposes, fixed by the Appellate Controller at Rs. 3,000 per acre, called for interference.

Analysis: The Revenue's valuation was based on five times the alleged net receipts from cotton cultivation, but the valuation was worked out on gross sale proceeds instead of net receipts. The sale instances of adjoining land placed before the appellate authority indicated rates of about Rs. 1,500 to Rs. 2,000 per acre, and the higher rate adopted by the Appellate Controller was considered reasonable on the material available.

Conclusion: The valuation adopted by the Appellate Controller was upheld and the Revenue's challenge was rejected.

Final Conclusion: The departmental appeal failed, and the relief granted in the valuation of the land remained undisturbed.

Ratio Decidendi: In valuing agricultural land, a valuation based on net receipts must not be founded on gross sale proceeds, and comparable sale instances may justify the market value adopted by the appellate authority.

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