India Automobiles (1960) Ltd vs Calcutta Municipal Corporation & Anr

The case concerns the determination of the annual valuation of a commercial property under Section 174 of the Calcutta Municipal Corporation Act, 1980. The primary legal issue is whether the annual value should be based solely on the rent actually received by the owner or if it should include the total amount paid by sub-tenants to the primary tenant. The Supreme Court examined the High Court's direction to the Tribunal to consider sub-tenancy rentals in the assessment of the annual valuation.