Finality of valuation reports under wealth-tax law: later revisions on administrative directions are invalid and original report governs.

A valuation report submitted under section 16A(5) becomes final for that exercise, and the Valuation Officer is functus officio once it is issued. Any later correction is confined to rectification of a mistake apparent from the record by the authority that made the original valuation; it cannot be reopened or revised on directions from a superior administrative authority. Directions altering valuation methodology or deductions amount to an impermissible review, not rectification. On the stated facts, the later valuation reports prepared under such directions were invalid, and the original valuation report remained the only lawful report for the wealth-tax assessments.

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Issues: Whether the revised valuation reports issued after the initial report were valid in law and whether the first valuation report had to be adopted for the wealth-tax assessments.

Analysis: The statutory scheme under section 16A contemplates a valuation exercise by the Valuation Officer, notice to the assessee, consideration of objections, and submission of a written estimate to the Wealth-tax Officer. Once that report is submitted, the Valuation Officer becomes functus officio so far as that valuation is concerned. Rectification under section 35(1)(aaa) and section 35(6A) is confined to correction of a mistake apparent from the record by the authority that made the original order. The power does not extend to revising a valuation at the instance of a superior administrative authority, and directions issued by such superiors to alter the manner of valuation or deductions amount to an impermissible review rather than rectification. On the facts, the subsequent reports were prepared pursuant to such outside directions and did not constitute valid rectification orders, while the original report under section 16A(5) remained the only lawful valuation report.

Conclusion: The revised valuation reports were invalid, and the Wealth-tax Officer was bound to adopt the initial valuation report.

Ratio Decidendi: After a valuation report is submitted under section 16A(5), it can be corrected only by the same authority for a mistake apparent from the record; superior administrative directions cannot be used to reopen or revise the valuation.

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