1984 (7) TMI 223

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....pears, the original assessment was made on the assessee for this year on 22nd Jan., 1977 in which values as returned by the assessee in respect of certain properties amounting to Rs. 3,33,766 were accepted and it is stated that this is the value adopted for the earlier asst. yr. 1975-76. However, for the asst. yr. 1977-78 the question of valuation of these properties, it is stated, was referred to....

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....essment year under consideration, namely 1976-77, especially regard being had to the position that each year is separate and independent and determination of any issue in one year does not act as estoppel or res judicata for any other year. Again, it is argued that almost all the properties which are subject matter of dispute in regard to the valuation are let out except one property, which is par....

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....information for the purpose of s. 17(1)(b) reference was made to two decisions of the Supreme Court in Maharaja Kumar Kamal Singh vs. CIT (1959) 35 ITR 1 (SC) and CIT vs. A. Raman & Co. (1966) 67 ITR 11 (SC). The ld. Departmental Representative contended in reply that the valuation report of the subsequent year does constitute proper information for the purpose of s. 17(1)(b) as held in the decisi....

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.... rent. The decisions sated on behalf of the assessee show that the rental method would be the proper one in such a case. In the present case it is seen that out so seven properties, six properties are let out properties and only one is partly used for residential purpose and partly for business. Secondly, it is seen that the valuation adopted for the asst. yr. 1977-78 itself has been substantially....