SABYASACHI MUKHARJI, J.

( 1 ) IN this reference we are concerned with the question of valuation of immovable property. In order to appreciate the question referred we will briefly state the facts. This reference is in respect of assessment to wealth-tax for the assessment years 1957-58 to 1962-63. The assessee purchased the house property (godowns) at Nos. 196, 197 and 198, Maharshi Devendra Road, Calcutta, in 1946 for a sum of Rs. 3,20,000. The said property bears three municipal numbers but the property is really one. It consists of very old godowns standing on an area of about 42 cottahs of land on the said Maharshi Devendra Road, opposite Mayo Hospital in Calcutta. It was let out to three different tenants. The net annual rents received from these godowns were) Rs. 10, 359 in the assessment years 1957-58 to 1960-61, Rs. 11,490 in the assessment year 1961-62 and Rs. 8,971 in the assessment year 1962-63. We are not quite aware as to the reasons for the variation of rents for the different years mentioned above. Counsel for the assessee suggested that perhaps it was due to the agreement or contract between the tenants and the landlord in question. The question arose about the val

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