Judgment Adarsh Kumar Goel, J. 1. At the instance of the assessee, the following questions of law have been referred for the opinion of this court by the Income-tax Appellate Tribunal, Amritsar Bench, Amritsar (for short, "the Tribunal"), under section 27(1) of the Wealth-tax Act, 1957 (for short, "the Act"), in respect of the assessment years 1974-75, 1975-76, 1976-77, 1978-79 and 1979-80 : "1. Whether, in view of the facts and circumstances of the case, the Tribunal was justified in ignoring the rental method, even when the property in question was entirely let out to various tenants ? 2. Whether, in view of the facts and circumstances of the case, the Tribunal was justified in upholding the assessment of the value of Shamlat Deh in the hands of the assessee ?" 2. The assessee-Hindu undivided family is a wealth-tax assessee and for the assessment years 1974-75, 1975-76,1976-77,1978-79 and 1979-80, the assessee declared the value of one immovable property being factory building at Tanda Road, Jalandhar, and valuation thereof was given as follows : 637-mk..kk.htm 3. The valuation was arrived at on the basis of the valuation certificate of a registered valuer who determined the valuation as a mean of the value determined by the land and building method and the rental method. Subsequently, the returns were revised and the value of the factory was declared at Rs. 1,48,500 on the basis of the rental method alone. The Assessing Officer did not accept this valuation and referred the matter to the Departments Valuation Officer who determined the valuation on the basis of the land and building method alone as under : 637-mk..ff.htm 4. On the basis of the above, the Wealth-tax Officer made the assessment for the relevant assessment years. The same was affirmed in appeal and also by the Tribunal in further appeal. 5. Regarding the method of valuation of immovable property, the Tribunal observed that the plea that the building should be valued on the basis of the rental method was not raised either before the authorities below nor in the grounds of appeal filed before it. It further observed that the assessee himself had not followed the rental method and had shown the valuation by taking the mean of the land and building and the rental method. It further observed that the assessee himself had not followed the rental method and had shown the valuation by taking the mean of the land and building and the rental method. The Tribunal, therefore, did not permit the assessee to raise the contention that the immovable property be valued on the basis of the rental method. The Tribunal, thereafter, upheld the valuation as determined by the District Valuation Officer on the merits as well. It observed that the District Valuation Officer had duly afforded an opportunity to the assessee to raise objections, if any, but the assessee failed to do so. Even before the Tribunal, the assessee had not brought any material to substantiate its challenge to the report of the District Valuation Officer that the valuation should have been made on the basis of the rental method. 6. The contention of the assessee that he was the owner only to the extent of 170 marlas out of 527 marlas, the remaining land being shamlat land, was also rejected on the ground that the assessee was having adverse possession for the period exceeding 12 years. It was also observed that no evidence was brought on record to show that he was not the owner of the entire land measuring 527 marlas. The Tribunal also found that in the past, the assessee had shown himself as the owner of the whole land and filed the wealth-tax returns as such since the year 1968-69. The Tribunal has further observed that no such plea was raised before the Assessing Officer. 7. Learned counsel for the assessee has reiterated the assessees stand taken before the Tribunal whereas counsel for the Revenue has supported the findings recorded by the Tribunal. 8. We have considered the rival submissions and perused the records of the case. 9. As far as question No. 1 is concerned, the Tribunal has held that the assessee was not entitled to raise the issue that the building be valued on the basis of the rental method which finding has not been questioned even in the present reference. Thus, question No. 1 in our considered view, is only of academic interest. 9. As far as question No. 1 is concerned, the Tribunal has held that the assessee was not entitled to raise the issue that the building be valued on the basis of the rental method which finding has not been questioned even in the present reference. Thus, question No. 1 in our considered view, is only of academic interest. Even otherwise, in view of the findings of fact recorded by the Tribunal that the assessee himself had not shown the valuation in his return of income on the basis of the rental method and had also failed to raise any objection to the valuation determined by the District Valuation Officer, it cannot be said that the action of the Assessing Officer in adopting the valuation as per the District Valuation Officers report was in any manner erroneous. It is also borne out from the record that the assessee had failed to bring any material on record to substantiate his claim about valuation even before the Tribunal. 10. Question No. 1 is, accordingly, answered in the affirmative, i.e., in favour of the Revenue and against the assessee. 11. Coming to the claim of the assessee that he was the owner of land only to the extent of 170 marlas out of the total area of 527 marlas, we find that the findings recorded by the Tribunal are pure findings of fact. It has not been disputed that the assessee had declared himself to be the owner of the whole land in the wealth-tax returns for the assessment years 1968-69 onwards. It is also not controverted that no such plea had been raised before the Assessing Officer nor any such objection taken before the District Valuation Officer. It is also not in dispute that the assessee has been in adverse possession of the land for more than 12 years. The Tribunal has also correctly observed that this issue had not been specifically raised in the grounds of appeal. In this factual background, we arc of the view that the Tribunal was justified in upholding the action of the Assessing Officer in assessing the entire land in the hands of the assessee. 12. Accordingly, question No. 2 is also answered in the affirmative, i.e., in favour of the Revenue and against the assessee.