Reasonable agricultural land valuation upheld where prior wealth-tax assessments and land quality supported the estimate.

Valuation of agricultural land for wealth-tax purposes was upheld where the Appellate Controller had fixed the property at Rs. 90,000 on the relevant date. The Department had already accepted a valuation of Rs. 84,000 in assessments close to the date of death, and the valuation report, together with the poor quality of the lands in two villages, supported the higher estimate. On those facts, the estimate was treated as reasonable and there was no basis to interfere with it at the Department's instance.

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Issues: Whether the estimated value of the agricultural lands at Rs. 90,000 was liable to be interfered with at the instance of the Department.

Analysis: The lands had already been accepted by the Department at Rs. 84,000 in the course of wealth-tax assessments close to the date of death. The Appellate Controller also relied on the valuation report and the poor quality of the lands in two of the villages. On the facts, the estimate of Rs. 90,000 was found to be a reasonable valuation of the property as on the relevant date.

Conclusion: The Department failed to show any reason to disturb the valuation fixed by the Appellate Controller, and the estimated value of Rs. 90,000 was upheld.

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