Wealth Tax Officer vs Surender Singh on 22 January, 2002
11. We have considered the rival submissions. We have perused the records. The assessee is owner of three plots in Ramesh Nagar, New Delhi, the value of which has been determined by the AVO on the basis of a sale instance of a constructed plot i.e., a building situated in Rajouri Garden. Rajouri Garden is opposite to Ramesh Nagar. The learned authorised representative has relied upon the case of CIT v. Miss '(Dr.) Vinay Rae (supra). In this case it was held that for the purpose of valuation of land the established principle of comparable cases of the vicinity should be followed. We find that the AVO has not relied upon any sale instance of the same vicinity and he has compared a built-up plot with open plot whereas the assessee has quoted a sale instance of the same locality. Instance of sale should be of similar plot' of land in similar locality.