Controlled procurement price governs valuation of unsold paddy when a price-control regime fixes the relevant accounting-year basis.

Where a statutory price-control regime governs the accounting year, unsold paddy must be valued by reference to the controlled maximum procurement price fixed for that year, not by an average locality price from the previous year. The controlled price structure displaces historical market averages for valuation purposes, so the entire stock held during the accounting year has to be computed on the basis of the applicable order. The valuation method therefore follows the operative price restriction in force during the relevant year, and the historical average price approach is rejected.

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Issues: Whether, on the facts and in the circumstances of the case, the market value of unsold paddy was to be determined under rule 4(2)(a) on the procurement rate fixed for the accounting year, rather than on the average locality price of the previous year.

Analysis: The accounting year had become academic in view of the procurement control regime and the price-fixing order governing the sale of paddy. The order fixed the maximum price at which paddy could be bought or sold in wholesale quantities, and the assessee's stock had to be valued in the light of that controlled price structure rather than by reference to an earlier year's average local price.

Conclusion: The question was answered in the negative, and the Tribunal was required to apply the maximum rate fixed by the relevant order to the entire quantity of paddy held by the assessee in the accounting year.

Final Conclusion: The reference was decided against the assessee on valuation of unsold paddy, with the controlled procurement price treated as the governing basis for computation.

Ratio Decidendi: Where a statutory or regulatory price-control regime governs the accounting year, market value for agricultural stock must be determined by reference to the controlled maximum price applicable during that year, not by an unrelated historical average price.

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