Judgment :- R. JAYASIMHA BABU, J. : The Tribunal, while approving the reasoning adopted by the CWT in his order by which the CWT had set aside the wealth-tax assessment and directed the WTO to redo the assessment after going into the entire gamut of the valuation of the properties concerned, by what was termed as slightly modification virtually set at naught the CWT's order. The direction, so given by the Tribunal, were not called for. Now the Revenue is before us questioning the directions given by the Tribunal. The question referred to us is as follows : "Whether on the facts and in the circumstances of the case, the Tribunal was right in law in modifying the direction of the CWT given under s. 25(2) and directing the AO to finalise the assessments for the asst. yrs. 1983-84 to 1986-87 on the basis of the value finally fixed for the properties concerned in the asst. yr. 1982-83 ?" The mere fact that the valuation report was received subsequent to the date of the assessment would not ipso facto make the valuation applicable to all the years upto the date of the assessment as the valuation made was with reference to a specific anterior date, namely, 13th April, 1982. The assessment years in question are later years 1983-84 to 1986-87. The CWT has rightly directed the WTO to redo the assessment for those years without binding him to adopt the report of the Valuation Officer given for the earlier year. The valuation is required to be made as on the valuation date and report given with regard to the value made for earlier valuation date, cannot in these circumstances ipso facto, apply for determining the valuation for later years. The question referred to us is, therefore, answered in favour of the Revenue and against the assessee.