MUNICIPAL CORPORATION, INDORE AND OTHERS vs SMT. RATNA PRABHA AND OTHERS

The Supreme Court held that under Section 138(b) of the Madhya Pradesh Municipal Corporation Act, 1956, the annual value of a building must reflect its reasonable letting value, which is not constrained by the standard rent under Section 7 of the Madhya Pradesh Accommodation Control Act, 1961, if the building has never been let out. The Court clarified that in cases where the property is used by the owner (as a hotel in this instance), the standard rent fixation does not apply, allowing for a higher valuation. The High Court's decision was reversed, affirming the Municipal Corporation's assessment.