JUDGMENT CHANDURKAR J.-At the instance of the assessee, the following question has been referred under section 27 (1) of the Wealth Tax Act:- "Whether in view of the provisions of section 7 (2) (a) of the Wealth Tax Act, the Wealth-tax Officer was justified in valuing the movable and immovable business assets in a manner different from written down value shown in the balance sheet? 2. In view of some controversy with regard to the scope of the question, it will be proper to reproduce the questions in respect of which the assessee had asked for a reference. These questions were: (1) Whether in view of the provisions of section 7 (2) (a) of the Wealth Tax Act, the Wealth-tax Officer was justified in valuing the machinery in a manner different from written down value shown in the balance sheet? (2) Whether there is any evidence to show that the value of the machinery has not depreciated as much as the depreciation allowed under the Income Tax Act? We shall refer to these questions a little later. 3. The Wealth-tax Officer while dealing with the assessments in respect of the assessment years 1958-59 to 1961-62 found from the balance sheet that in respect of immovable property, the value of the property shown in the balance sheet was arrived at after deducting Rs. 2,54,648 which was initial and additional depreciation and in respect of the movable property the value was shown after taking into account initial and additional depreciation in respect of machinery to the extent of Rs. 1,18,631. These two figures were, therefore, added to the total wealth of the assessee while computing the net wealth. The assessee challenged these additions to the net wealth in appeal which was decided by the Appellate Assistant Commissioner before whom it was contended that since the entire business was to be valued as per global valuation method, the actual values of such assets as shown in the respective balance sheets for the assessment years under appeal ought to have been accepted without adding back the initial and additional depreciation. Rejecting this contention the Appellate Assistant Commissioner observed: "It is a matter of Common knowledge that the assets do not depreciate to the same extent as the total amount of depreciation, ordinary, initial and additional allowed under the Indian Income Tax Act, 1922 and the rules framed thereunder. Rejecting this contention the Appellate Assistant Commissioner observed: "It is a matter of Common knowledge that the assets do not depreciate to the same extent as the total amount of depreciation, ordinary, initial and additional allowed under the Indian Income Tax Act, 1922 and the rules framed thereunder. Since the actual value of business assets bas to be taken for purposes of ascertaining the appellant's total wealth and since such value was very much more than the value arrived at by the Wealth-tax Officer after adding back the initial and additional depreciation by reason of the fact that assets such as machinery and plant had appreciated in value due to the restriction of imports of similar machinery, and that immovable properties had also appreciated in value due to the demand for such assets being very much more than the limited supply, I hold that the Wealth-tax Officer was justified in computing the value of such order by adding back the initial and additional depreciation allowed under Rule 8 of the Income-lax Rules.” Thus the Appellate Assistant Commissioner confirmed the order of the Wealth-tax Officer. 4. The assessee took the matter in appeal to the Tribunal. We are not concerned with the other parts of the order of the Appellate Assistant Commissioner challenged in appeal. But so far as the contention with regard to the addition of the initial and additional depreciation was concerned, the Tribunal reproduced the argument advanced on behalf of the assessee as follows:- "According to Mr. Mulla, such an adjustment was not called for. According to him once the global method is adopted, the value of the assets as shown in the accounts would be the value for ascertaining the net wealth. It was also submitted by him that if the value as per the balance sheet could not be accepted it may be a matter for ascertaining the correct value as per the other provisions of the Act." The Tribunal, however, dismissed the appeals holding that in the peculiar circumstances of the case and in view of the reasons given by the Appellate Assistant Commissioner, viz., the appreciation in the cost of machinery and building, he was justified in making adjustments by adding back the initial and additional depreciation. It is out of this order that according to the assessee, the two questions of law, which we have reproduced above, arose. It is out of this order that according to the assessee, the two questions of law, which we have reproduced above, arose. We, however, find that the second question, which, according to the assessee, arose out of the order of the Tribunal, has not been referred. So far as the first question, which, according to the assessee, had to be referred, is concerned, certain alterations were made inasmuch as in place of the words "the machinery", "the movable and immovable business assets" were substituted. Substantially, therefore, it is the first question, which, as framed by the assessee, was restricted to the value of the machinery which was referred after making certain alterations. Even in the second question which was sought to be referred, the assessee himself had referred only to the machinery. 5. Now, when the reference was taken up for hearing, Mr. Dastur on behalf of the assessee has vehemently contended that having regard to the grounds of appeal before the Tribunal, a copy of which has been made available to us, the first question must be so construed as to take within its scope even a challenge to the finding recorded by the Appellate Assistant Commissioner and confirmed by the Tribunal that there was no depreciation whatsoever actually in respect of the assets and that the values of the machinery and of the building assets had actually appreciated and, therefore, the Wealth-tax Officer was justified in adding back the amount of initial and additional depreciation. It is difficult for us to accept the contention that the question must be read as widely as it is contended on behalf of the assessee. We have reproduced above in extenso the kind of challenge to the order of the Appellate Assistant Commissioner, which was made before the Tribunal. It is no doubt true that so far as the grounds of appeal before the Tribunal are concerned, the finding given by the Appellate Assistant Commissioner that the assets do not depreciate to the same extent as the total amount of depreciation allowed under the Income tax Act has been challenged. We should, however, be guided more by the nature of the case argued before the Appellate Tribunal than the grounds of appeal because it is common experience that all matters which are raised in the grounds of appeal are not necessarily argued at the final stages of the litigation. We should, however, be guided more by the nature of the case argued before the Appellate Tribunal than the grounds of appeal because it is common experience that all matters which are raised in the grounds of appeal are not necessarily argued at the final stages of the litigation. The part of the order of the Tribunal which we have extracted above clearly shows that the only contention before the Tribunal was that the balance sheet should have been accepted by the Wealth-tax Officer and that if the balance sheet could not be accepted as reflecting the correct value of the assets, then some other provisions of the Act could have been invoked. What other provisions of the Act were referred to in the contention, it is not possible to ascertain at this stage. But what is clear is that what was challenged before the Tribunal was the jurisdiction of the Wealth-tax Officer to pick and choose an item out of the balance sheet and determine its market value after rejecting the value as shown in the balance sheet. If this was only limited argument before the Tribunal, the mere fact that while confirming the order of the Appellate Assistant Commissioner the Tribunal has observed that the additions and the adjustments by adding back initial and additional depreciation were justified will not enable the assessee to canvass in this reference the contention that the Appellate Assistant Commissioner and the Tribunal were in error in proceeding on the footing that the values of the movable and the immovable assets of the assessee had in fact appreciated and not depreciated. The observations made by the Tribunal in the concluding part of the order must be read in the light of the contention raised before the Tribunal. While disposing of the appeal the Tribunal, in the view, which it had taken, was bound, while concluding the order, to confirm the order of the Appellate Assistant Commissioner and it is this which the Tribunal has done. While disposing of the appeal the Tribunal, in the view, which it had taken, was bound, while concluding the order, to confirm the order of the Appellate Assistant Commissioner and it is this which the Tribunal has done. Therefore, the observation of the Tribunal that the view of the Appellate Assistant Commissioner that the assets had appreciated was justified read in the light of the fact that no challenge was canvassed before the Tribunal with regard to the finding as to whether the assets had appreciated or not could not be read as indicating that the Tribunal was called upon to consider the correctness of the finding regarding appreciation of the assets recorded by the Appellate Assistant Commissioner. On the order of the Tribunal, therefore, and having regard to the contention raised before it, the question referred to us must be read as merely putting in issue the contention of the assessee before the Tribunal that while taking recourse to the global method of valuation, the balance sheet must be accepted as it is and that the Wealth-tax Officer was not entitled to add to any of the items in the balance sheet. This view of ours is confirmed by the fact that the Tribunal has not chosen to refer question No.2 which we have reproduced above and which on the application of the assessee, it appears, he wanted it to be referred. There is indication in the order of the Tribunal itself to show that even at the stage of reference what was canvassed was only one question because in the opening part of the order, the Tribunal has observed that the assessee has required the Tribunal to draw up a statement of the case and refer one question said to be a question of law arising out of the order of the Tribunal. Mr. Dastur has contended that in Commissioner of Income-tax, Bombay v. Scindia Steam Navigation Co. Ltd.1, the Supreme Court has held that when a question of law is raised before the Tribunal; but the Tribunal fails to deal with it, it must be deemed to have been dealt with by it and, therefore, it is a question arising out of its order. Ltd.1, the Supreme Court has held that when a question of law is raised before the Tribunal; but the Tribunal fails to deal with it, it must be deemed to have been dealt with by it and, therefore, it is a question arising out of its order. Now, apart from the grounds of appeal before the Tribunal, which are now produced before us, there is nothing in the order of the Tribunal which shows that the question with regard to the finding of the Appellate Assistant Commissioner that the assets had not actually depreciated was ever canvassed and there was no question, therefore, of the Tribunal declining to deal with it. As already observed, merely because a ground is raised in the grounds of appeal, it cannot be assumed that the ground was canvassed and that the Tribunal had declined to consider it. 6. Thus the question, which is referred, must now be construed as indicating that according to the assessee, once the global method of valuation is resorted to, no additions could be made to any items in the balance sheet. It is too late in the day to canvass such a contention. The power of the Wealth tax Officer to ascertain the true value of the assets in a case in which the global method of valuation is resorted to under section 7 (2) (a) of the Income-tax Act has been dealt with by the Supreme Court in a series of decisions commencing with the decision in Kesoram Industries and Cotton Mills Ltd. v. Commissioner of Wealth-tax (Central) Calcutta2, and ending With the latest pronouncement as far as we are aware in Commissioner of Wealth-tax, Calcutta v. Hindustan Motors Ltd.3. The Supreme Court has held in all these cases that the object of the Wealth-tax Officer in determining the value of the assets under section 7 is to arrive at the value of the assets of the business and if what has been shown in the balance sheet is not the true value of the assets disclosed, it is open to the assessee to satisfy the Wealth tax Officer by producing relevant materials that the value given of the fixed assets in the balance sheet is not the true value and, therefore, the reduced value of the assets should be taken into account. The effect of the decisions of the Supreme Court with regard to the scope of the powers of the Wealth-tax Officer in a case where he resorts to the global method of valuation is that he is not bound to accept the valuation in the balance sheet as final and whoever wants to challenge that valuation must place sufficient material before the Wealth· tax Officer to show that the valuation as shown in the balance sheet is not correct. 7. In this view of the matter, the Wealth-tax Officer bad ample jurisdiction to go into the question as to whether the value of the movable and immovable assets of the assessee as reflected in the balance sheet was the true market 'value or whether any adjustments were necessary. The question referred must, therefore, be answered in the affirmative and in favour of the assessee. Question is accordingly answered. The assessee to pay the cost of the revenue. Reference answered in affirmative.