1. This common judgment shall dispose of Income-tax Appeals Nos. 4 and 5 of 1982.

2. These appeals arise out of the judgment of the Income-tax Appellate Tribunal (hereinafter referred to as "the ITAT") delivered on September 10, 1981. Shri Gobind Ram, son of Damodar Dass and Shri Hari Shanker, son of Shri Babu Lal, purchased a building situated at Narnaul from Shri Om Parkash, son of Shri Moti Lal Aggarwal, for a consideration of Rs. 35,000 as per sale deed registered at No. 77 dated April 24, 1973, with the Sub-Registrar, Narnaul. The building is having a land area of about 5,000 sq. yards and it consists of a number of rooms being used as godown and factories and,ten shops facing a road of about 10 ft. wide. It is a single-storeyed building.

3. A reference under Section 269L of the Income-tax Act, 1961 (hereinafter referred to as "the Act"), was made to the Valuation Officer, Income-tax Department, Rohtak. The Assistant Valuation Officer, Income-tax Department, Rohtak, vide his report dated December 27, 1973, determined the fair market value of the property at Rs. 39,257 on the "rent capitalisation" method as the whole of the property was in the occupation of the tenants.