Nil valuation of nationalised company shares upheld where compensation was uncertain and no real market value existed.

Shares in a nationalised colliery company may be valued at nil for wealth-tax purposes where compensation is uncertain or unpaid and the shares therefore have no presently ascertainable market value. On those facts, book value adopted by the Wealth-tax Officer was not sustainable, especially where the same family's shares had already been treated as nil in another assessment and no basis was shown to depart from that approach. The nil valuation was upheld and the departmental addition was not restored.

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Issues: Whether the value of the assessee's shares in a nationalised colliery company was rightly taken at nil for wealth-tax purposes instead of at the book value adopted by the Wealth-tax Officer.

Analysis: The shares related to a colliery company taken over under nationalisation legislation, and the record showed that the compensation, if any, was uncertain and had not been paid. In such circumstances, the possible compensation could not be treated as giving the shares a real market value. The same assessee family's shares in the company had also been treated as having nil value in another assessment, and no reason was shown to depart from that approach. The valuation adopted by the Wealth-tax Officer was therefore not sustainable.

Conclusion: The valuation of the shares at nil was upheld and the addition made by the Wealth-tax Officer was not restored.

Final Conclusion: The departmental challenge to the deletion of the share valuation failed, and the assessee's valuation was accepted for wealth-tax computation.

Ratio Decidendi: Where shares of a nationalised company have no presently ascertainable market value because compensation is uncertain or unpaid, they may be valued at nil for wealth-tax purposes.

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