Additional evidence on car valuation tax was remanded for fresh consideration after authorities failed to examine material proof.

Additional evidence on Hong Kong registration tax was treated as material to the correct assessable value of a second-hand car, because it went to the root of valuation and was said to have been obtained only after the impugned order. The authorities were therefore required to examine the evidence before finalising value, and the valuation issue was remanded to the jurisdictional Assistant Commissioner for fresh consideration in accordance with law after giving the appellants an opportunity of hearing.

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Issues: Whether additional evidence relating to deduction of Hong Kong registration tax in the valuation of a second-hand car should be considered and the matter remanded for reconsideration.

Analysis: The evidence concerning registration tax was claimed to be an important material document for determining the correct assessable value, and it was not produced earlier because it was obtained only after the impugned order. Since the evidence went to the root of valuation, the authorities below were required to examine it before finalising the assessable value. The matter was therefore fit to be sent back for fresh consideration by the jurisdictional Assistant Commissioner after granting an opportunity to the appellants.

Conclusion: The additional evidence was to be examined and the valuation issue was remanded for fresh decision in accordance with law after hearing the appellants.

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