( 1 ) THIS is a reference under Section 27 (1) of the Wealth Tax Act (XXVII of The assessee Srimathi Manyam Meenakshamma, a resident of Rajahmundry was assessed to a total wealth of Rs. 5,19,191by the Wealth Tax Officer in regard to the assessment year 1957-58 for which the relevant valuation date is 31-3-1957. She owned extensive immovable properties, including forest and agricultural lands and buildings situated at various places. The forest measuring about 200 sq. miles was valued by her at Rs. 21,000. The Wealth Tax Officer, however, determined its value to be Rs. 2,00,000 as he found that the average income during the last three assessment years was Rs. 10,000 and capitalized this income 20 times. The agricultural lands had been taken over by the Government under the Estates (Abolition and Conversion into Ryyotwari) Act (XXVI of 1948 ). The Wealth Tax Officer included the balance of Rs. 71,279 of the compensation amount payable to the assessee in her total wealth for the purpose of the assessment. As regards the buildings, it is relevant only to mention that a house property at Yanam was valued by the assessee at Rs. 5,000 but the Wealth Tax Officer fixed it as