Estate duty land valuation upheld where comparable sales supported the appellate rate and gross cotton proceeds were rejected as a base.

Estate duty valuation of 8.5 acres of cotton-growing land was assessed by reference to net receipt rather than gross cotton sale proceeds, because a five-times multiplier cannot be applied on gross turnover when the underlying basis is net income. Comparable sales of adjoining land supported the appellate valuation, with market instances around Rs. 1,500 to Rs. 2,000 per acre making the adopted figure of Rs. 3,000 per acre reasonable. The valuation fixed by the Appellate Controller was therefore upheld and the revenue challenge failed.

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Issues: Whether the valuation fixed for 8.5 acres of cotton-growing land for estate duty purposes required interference, particularly where the revenue basis was gross cotton sale proceeds and the appellate valuation relied on comparable sales of adjoining land.

Analysis: The estimate made on the basis of five times the net receipt could not rest on gross sale proceeds alone, because the underlying premise was net income and not gross turnover. The appellate valuation was supported by instances of sale of adjoining land showing a range of about Rs. 1,500 to Rs. 2,000 per acre, and the figure adopted at Rs. 3,000 per acre was found to be reasonable in the circumstances.

Conclusion: The valuation fixed by the Appellate Controller was upheld and the revenue's challenge failed.

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