RUTTY RAJAMMANNAR Vs. COMMISSIONER OF INCOME TAX

JUDGEMENT

(1.) THE assessee in this case possessed 17 items of immovable properties in respect of which he adopted the valuation of Rs. 3,53,626 which was accepted by the wealth-tax authorities for the assessment year 1960-61. THE WTO, for the assessment year 1965-66, found that according to the Inspector's report, the value of all the items of properties would be Rs. 19,33,247. However, after visiting personally every property and taking into consideration several other factors, he valued all the properties at Rs. 16,29,061.

(2.) THE assessee went in appeal to the AAC. He applied different methods of valuation depending upon the location and the extent of the properties. In respect of houses which had considerable vacant land around them, he determined the value of the house with the appurtenant land and of the excess land separately. He also adopted a different basis in respect of properties situate in Netaji Subhas Chandra Bose Road which he considered very valuable. As regards the properties situate at Harrington Road, the AAC felt that the adoption of the rental method would be highly unrealistic. THErefore, in valuing the properties, he adopted the split up yield method as adopted by the WTO, but reduced the value of the land from Rs. 10,000 to Rs. 9,000 per ground in respect of properties at Harrington Road. However, in respect of properties situate in Netaji Subhas Chandra Bose Road, the AAC arrived at the valuation by adopting the mean between the value based on the rental method and the value based on the building-cum-site method and granted relief in a sum of Rs. 66,083.

(3.) IT is seen from the question referred that this reference covers only door Nos. 56, 61, 62 and 63, Harrington Road, Madras, and door Nos. 178 and 179, Netaji Subhas Chandra Bose Road, Madras, and that we are not concerned with the valuation of the other items of properties. After a due consideration of the matter, we are inclined to agree with the method of valuation adopted by the Tribunal.