TaxTMI 
TaxTMI 
1980 (4) TMI 140
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....aving 3/16th share in the firm of M/s V.M.K. Marimuttu Nadar. In this re-assessment the Asst. Contr. Of ED reworked the interest of the deceased in the partnership by revaluing the immovable properties as belonging to the firm. These properties consisted of a Dal Factory and an Oil Factory. The dispute centres round both the reopening of the assessment as well as the revaluation of the immovable properties. However, at the time of hearing the learned counsel for the accountable person did not press the ground relating to the reopening of the assessment under s. 59(b). 2. The accountable person filed valuation report in respect of the immovable properties. The Dal factory was located in an area of 64,302 sq. ft. in the Nehru Ganj area of ....
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....ue adopted by A.P. Dep. Value adopted by A.P. Dept. 64,302 sq. ft. . 30,100 sq. ft. . Rs. 64,302—@Rs. 1 Rs.3,21,510 @Rs. 5 Rs. 1,50,500 @Rs. 5 24,080 @ Rs. 080 DAL FACTORY OIL FACTORY . Dept A.P. Dept. A.P. . . Rs. Rs. Rs. Rs. . . 1,68,360 84,600 79,344 40,500 . Office Bldg.& staff quarters 1,64,887 1,44,100 Godown & staff quarters 1,39,744 1,16,460 Capla factory 74,700 46,800 . . . The net result of the above figures is that the total value taken on both the factories was Rs. 10,99,045. He gave a deduction of 5 per cent as discussed above and fixed the value at Rs. 10,44,093. 3/16th share of the declared was....
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....e valuer's report does not show any details so does the valuation made by the Department. There is no basis for adopting the rates as adopted by the taxing authorities. At any rate there are no comparable cases of factories where this rate had been adopted. On the other hand, the departmental representative relied on the order of the Appellate CED. 6. Having considered the matter we are of the opinion that as far as the value of the land is concerned the finding of the Appellate Controller has to be upheld. The data taken note of show that the dal factory site was purchased in 1964 at the rate of Rs. 0.60 per sq. ft. The Sub-Registrar's valuation in March, 1976 showed Rs. 2.50 per sq. ft. The City Planning rate for 1976 was Rs. 2 per sq.....
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....s Inside the factory store room is provided with R.C.C. roof. The main factory building is built in random rubble masonry including foundation. The basement and super structure is in lime mortar and plastered over with cement mortar both inside and outside. The flooring is of Shahabad Stones set in cement mortar. All the joineries are of country wood. Electrical installations have been provided to the minimum extent. Even the office building and residential portion are built in random rubble masonry in lime. The walls are in brick masonry in lime mortar plastered with cement both inside and outside. Flooring consists partly of cement and partly of Shahabad Stones set in cement mortar. The joineries are of country wood and painted. The descr....