Retrospective valuation rules and capitalisation multiples under wealth-tax are applied based on pending assessments and property character.

Section 7(4) of the Wealth-tax Act was treated as a procedural valuation provision and, on that basis, applied to assessments pending when it came into force; the valuation accepted for an earlier year in respect of the self-occupied property was carried forward for the year under discussion. For the commercial let-out property, the capitalisation multiple for net maintainable rent was reduced from 12 to 10 because no reason was given for the higher figure and the property's commercial, let-out character supported the lower multiple. The overall result was that the Revenue's challenge failed and the assessee obtained relief on the valuation method applied.

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Issues: (i) whether section 7(4) of the Wealth-tax Act, 1957 applies retrospectively to pending assessments and permits adoption of the valuation fixed for an earlier assessment year for a self-occupied property; and (ii) whether the appropriate multiple for capitalisation of net maintainable rent for the commercial let-out property was 12 or 10.

Issue (i): whether section 7(4) of the Wealth-tax Act, 1957 applies retrospectively to pending assessments and permits adoption of the valuation fixed for an earlier assessment year for a self-occupied property.

Analysis: The provision was treated as procedural. On that basis, it was held to govern assessments pending on the date of its introduction. The valuation accepted for the earlier assessment year in respect of the self-occupied portion was therefore to be carried forward for the year under appeal.

Conclusion: In favour of the assessee. Section 7(4) was held to be procedural and retrospective, and the earlier valuation of the self-occupied property was rightly applied.

Issue (ii): whether the appropriate multiple for capitalisation of net maintainable rent for the commercial let-out property was 12 or 10.

Analysis: No reason had been given for adopting the multiple of 12. On the facts, the property being commercial and let out, the multiple was considered reducible to 10.

Conclusion: In favour of the assessee. The capitalisation multiple was reduced from 12 to 10.

Final Conclusion: The Revenue's challenge failed, while the assessee obtained relief on the valuation multiple for the commercial property.

Ratio Decidendi: A procedural valuation provision applicable to pending matters may operate retrospectively, and an unsupported capitalisation multiple may be reduced where the nature of the property so warrants.

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