https://www.taxtmi.com/caselaws?id=69057 For capital gains purposes, a valuation adopted in wealth-tax proceedings is only evidentiary and not conclusive when determining fair market value as on 1-1-1964. A valuation stated in a return or adopted in another tax proceeding is treated as an opinion, not as an admission creating estoppel, because there is no estoppel in tax matters. The assessee may therefore challenge the earlier figure and rely on other material showing a higher market value. Evidence of an adjacent property sale in April 1964 was accepted as relevant, and the prior wealth-tax valuation was treated as routine and insufficiently examined, leading to acceptance of the higher fair market value for capital gains computation. en-us Tue, 26 May 1992 00:00:00 +0530 Mon, 04 Apr 2011 17:59:32 +0530 TaxTMI RSS Generator https://www.taxtmi.com/caselaws?id=69057 For capital gains purposes, a valuation adopted in wealth-tax proceedings is only evidentiary and not conclusive when determining fair market value as on 1-1-1964. A valuation stated in a return or adopted in another tax proceeding is treated as an opinion, not as an admission creating estoppel, because there is no estoppel in tax matters. The assessee may therefore challenge the earlier figure and rely on other material showing a higher market value. Evidence of an adjacent property sale in April 1964 was accepted as relevant, and the prior wealth-tax valuation was treated as routine and insufficiently examined, leading to acceptance of the higher fair market value for capital gains computation. Case-Laws Income Tax Tue, 26 May 1992 00:00:00 +0530 https://www.taxtmi.com/caselaws?id=69057