Valuation by rental capitalisation upheld where valuer's report was unreliable, with repairs deduction corrected on recomputation.

Where an approved valuer's report is found unreliable on concurrent factual findings, it is not binding or conclusive evidence of market value under the Estate Duty Act. In that situation, the authority may validly determine the principal value by capitalising the net annual rental in the open market, and the court will not interfere with the factual appreciation of valuation evidence. The only correction required was on repairs: the deduction had to be taken at one-sixth of rent, not one-twelfth, so the valuation was upheld subject to recomputation on that limited point.

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Issues: Whether the approved valuer's report on the market value of the property could be treated as binding or conclusive, and whether the authorities were justified in valuing the property by capitalising net annual rental, while allowing a different rate of deduction for repairs.

Analysis: Under section 36 of the Estate Duty Act, 1953, the principal value is the price the property would fetch in the open market at the deceased's death. The approved valuer's report was concurrently found by the assessing authority and the appellate authority to be unreliable and inaccurate, and therefore it could be rejected as evidence. In the absence of dependable valuation evidence, the authorities were entitled to adopt the rental method and capitalise the net annual rent to determine market value. The only error identified was in the allowance for repairs: the deduction should have been taken at one-sixth of the rent rather than one-twelfth, so the figures required recalculation to that limited extent.

Conclusion: The approved valuer's report was not binding and its rejection was justified. The valuation by rental capitalisation was valid, but the deduction for repairs had to be increased from one-twelfth to one-sixth of the rent.

Final Conclusion: The valuation determination was upheld in principle, subject only to recomputation of the net rental value by allowing the higher deduction for repairs.

Ratio Decidendi: Where a valuation report is found unreliable, the authority may determine market value on a rental-capitalisation basis, and the court will not reappreciate concurrent findings of fact on the evidence.

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