Wealth-tax valuation of acquired land compensation must reflect existing awards, not a pending claim for enhanced compensation.

For wealth-tax purposes, the asset was the right to receive compensation for acquired land, and its value had to be estimated on the relevant valuation date with regard to the existing award and litigation risk. A pending claim for enhanced compensation before the Supreme Court did not itself become the asset's value, so the higher claimed amount was not includible. The High Court-determined compensation was the proper basis of valuation, and the additions made by the Wealth Tax Officer were deleted.

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Issues: Whether, for wealth-tax purposes, the assessee's right to receive compensation for acquired land had to be valued at the amount of enhanced compensation claimed before the Supreme Court or at the compensation already determined by the High Court.

Analysis: The assessee's property interest was the right to receive compensation for the acquired land, and that right had to be valued on the relevant valuation date. The compensation claimed in further appeal before the Supreme Court was only a pending claim and did not, by itself, become the value of the asset. The valuation had to reflect the existing award and the surrounding circumstances, including the uncertainty and risk attached to further litigation. The amount quantified by the High Court was therefore the proper basis for wealth-tax valuation, not the higher sum claimed in the pending appeal.

Conclusion: The enhanced amount claimed before the Supreme Court was not includible as such in the wealth-tax valuation, and the compensation as determined by the High Court was correctly taken as the value of the asset.

Final Conclusion: The additions made by the Wealth Tax Officer were rightly deleted, and the departmental appeals failed.

Ratio Decidendi: For wealth-tax purposes, a pending claim for further compensation is not itself the value of the asset; the right to receive compensation must be estimated on the valuation date with regard to existing awards and litigation risk.

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