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Valuation of property for assessment years 1984-85 to 1987-88 under Wealth-tax Act, 1957. Analysis: The judgment pertains to the valuation of a property for assessment years 1984-85 to 1987-88 under the Wealth-tax Act, 1957. The assessee, a Hindu undivided family, constructed a house property in Madras, which was completed in February 1984 and occupied for residential purposes immediately after. The Wealth-tax Officer valued the property significantly higher than the assessee's declared value, based on the Valuation Officer's assessment. The Commissioner (Appeals) directed the valuation to be computed using rule 1BB for the assessment year 1984-85 and extended the same value for the subsequent years under section 7(4) of the Act. The Tribunal upheld the Commissioner's decision for 1984-85 and determined that the property's value for the following years should be based on its market value as of March 31, 1984, which was returned at a lower amount by the assessee. The Tribunal considered the conditions under section 7(4) for valuation, requiring exclusive residential use for 12 months preceding the valuation date. While the property did not meet this condition for 1984-85, it was deemed a residential quarter despite limited use by the family. The Tribunal applied rule 1BB for the assessment year 1984-85, in line with judicial precedents like Gaj Singh v. Settlement Commission and CWT v. Sharvan Kumar Swsarup and Sons. Regarding the subsequent years, the Tribunal correctly determined that the property's value should be based on its market value as of March 31, 1984, in accordance with section 7(4). The Tribunal's decision to set aside the Commissioner's order for 1985-86 to 1987-88 and uphold the Revenue's appeal was deemed appropriate, as the property's value was correctly assessed at Rs.15,86,143 for each of these years. In conclusion, the Tribunal's decision was found to be legally sound, and the question referred against the Revenue was answered in favor of the assessee. The judgment provides a comprehensive analysis of the valuation principles under the Wealth-tax Act, emphasizing the importance of market value and statutory provisions in determining property value for assessment purposes.
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