Judgment ( 1. ) THE decision rendered in this appeal shall also govern disposal of other connected appeals being WT Appeal Nos. 35, 36, 37, 38 and 39 of 2004, as all these appeals involve identical points and are between the same parties, except the difference being that they arise out of different assessment years. ( 2. ) THIS is an appeal filed by CWT (Revenue), under Section 27a of the WT Act, against an order dt. 18th Nov. , 2003, passed by Tribunal in WTA Nos. 8, 9, 10, 11, 12 and 13/ind/2003. The appeal was admitted for final hearing on following substantial questions of law: 1. Whether the method adopted by the Tribunal in reducing the valuation of the land in question is legally sustainable and if so, on what ground ? 2. In view of the Collectors guidelines, could the property be valued at a lesser value than the one to be determined on the basis of Collectors valuation ? ( 3. ) FACTS of the case lie in a narrow compass. They, however, need mention in brief. ( 4. ) IN substance, the dispute relates to valuation of plot of land measuring around 39,200 sq. ft. out of 47,916 sq. ft. , situated at Palasia Hana (New Palasia), Ward No. 41, Survey No. 93, Indore, under the WT Act and the Rules framed thereunder. The question arose in the wealth-tax assessment years in question i. e. (1987-88 to 1997-98) as to what should be the correct valuation of the land in question for the purpose of payment of wealth-tax by the assessee (respondent herein) in these assessment years. The AO determined the value of the land at Rs. 1,200 per sq. ft. The CWT (A) determined at the rate of Rs. 1,100 per sq. ft. In other words, the CWT (A) reduced the valuation by Rs. 100 and determined at Rs. 1,100 per sq. ft. in place of Rs. 1,200 per sq. ft. as determined by AO. However, in further appeals filed by assessee as also by Revenue, the Tribunal by impugned order determined at Rs. 125 per sq. ft. In other words, in the opinion of Tribunal, the valuation of land should be determined at the rate of Rs. 125 per sq. ft. So AO said Rs. 1,200 per sq. ft. whereas CWT (A) said Rs. 1,100 per sq. ft. whereas Tribunal said Rs. 125 per sq. ft. In other words, in the opinion of Tribunal, the valuation of land should be determined at the rate of Rs. 125 per sq. ft. So AO said Rs. 1,200 per sq. ft. whereas CWT (A) said Rs. 1,100 per sq. ft. whereas Tribunal said Rs. 125 per sq. ft. It is against this order of Tribunal reducing the rate from Rs. 1,200 per sq. ft. to Rs. 125 per sq. ft. of the land in question, the Revenue has come up in appeal. So far as assessee is concerned, he is satisfied with the rate determined by the Tribunal i. e. Rs. 125 per sq. ft. as against Rs. 1,200 per sq. ft. by AO and Rs. 1,100 per sq. ft. by CWT (A) and hence, he has not come up in any appeal for further reduction from Rs. 125 per sq. ft. ( 5. ) HEARD Shri R. L. Jain, learned senior counsel with Ku. V. Mandlik, learned Counsel for the appellant and, Shri G. M. Chafekar, learned senior counsel with Shri D. S. Kale, learned Counsel for the respondent. ( 6. ) HAVING heard learned Counsel for the parties and having perused record of the case, we are constrained to allow the appeal and while setting aside of the impugned order passed by the Tribunal, remand the case to the Tribunal for deciding the appeal afresh on merits strictly in accordance with law. ( 7. ) THE question as to how the value of assets other than cash is to be determined is governed by Section 7 r/w Sch. III of WT Act. It reads as under: Section 7 (1)-Subject to the provisions of Sub-section (2), the value of any asset, other than cash, for the purposes of this Act shall be its value as on the valuation date determined in the manner laid down in Sch. III. Rule 1 of Sch. HI in Part A appended to the Schedule reads as under: Rule 1. Value of assets how to be determined.-The value of any asset, other than cash, for the purposes of this Act, shall be determined in the manner laid down in these rules. ( 8. III. Rule 1 of Sch. HI in Part A appended to the Schedule reads as under: Rule 1. Value of assets how to be determined.-The value of any asset, other than cash, for the purposes of this Act, shall be determined in the manner laid down in these rules. ( 8. ) WHAT we have noticed on perusal of impugned order of Tribunal is that there is no finding much less categorical finding recorded therein as to whether impugned valuation of land which is subject-matter of proceedings under challenge is in conformity with the requirement of Section 7 (1) r/w Sch. HI ibid or not. In fact, in the entire decision, we have not been able to notice even reference having been made of Section 7 (1) and the requirement contained in Sch. III. In our humble view, such determination made by Tribunal of an asset (land), is not legally sustainable and hence, deserves to be set aside on this ground alone, ( 9. ) IN order to determine the real value of the assets belonging to assessee for the purpose of WT Act, the valuation has got to be made keeping in view the statutory provision contained in Section 7 (1) r/w Sch. HI ibid, referred supra. The authorities while examining the issue in the context of requirement of Section 7 (1) r/w Sch. III can take into account any other material factors if law permits them to be taken note of. This can be ascertained from any judicial precedent, if it is governing the issue. Any deviation from this or an approach of the authorities de hors these requirements vitiates the valuation made. We find that this mistake is committed in this case by the Tribunal who has simply gone on factual aspects of the case thereby totally ignoring the requirement of Section 7 (1) r/w Sch. III while determining the value of land and then arriving at the conclusion that the rate is at Rs, 125 per sq. ft. as against what was determined by AO at Rs. 1,200 per sq. ft. and then reduced by appellate authority to Rs. 1,100 per sq. ft. We do not concur with this view of Tribunal, nor do we concur with the reasoning and the rate reduced drastically from Rs. 1,100 to Rs. 125. ( 10. ft. as against what was determined by AO at Rs. 1,200 per sq. ft. and then reduced by appellate authority to Rs. 1,100 per sq. ft. We do not concur with this view of Tribunal, nor do we concur with the reasoning and the rate reduced drastically from Rs. 1,100 to Rs. 125. ( 10. ) LEARNED counsel for the assessee (respondent) with vehemence urged that view taken by the Tribunal being based on pure appreciation of facts and evidence brought on record and hence, any finding based on facts cannot be disturbed in this appeal, it being pure finding of fact. Learned counsel further urged that even apart from this, no fault can be noticed in the approach of the Tribunal who has taken pains to examine the entire facts of the case such as status of land, its involvement in litigation prior to date of sale, the rate mentioned in the agreement entered into by the parties, etc. According to learned Counsel, all these factors being material while determining the rate and hence, the finding arrived at by the Tribunal cannot be said to be either arbitrary or illegal. We do not agree for the reasons stated supra. In other words, these submissions have been met by us supra against the assessee and hence, we cannot accept these submissions. ( 11. ) IN our humble view, while answering the question No. 1, we do possess the power to remand the case by taking recourse to the provisions of Section 27a ibid. Indeed, power to remand is inbuilt in Section 27a, if we come to a conclusion that no material finding as contemplated under the Act is rendered. ( 12. ) IN the absence of any finding as taken note of supra, this Court may not be able to decide the issue de novo in its specified and limited jurisdiction conferred under Section 27a ibid. It is for this reason, we consider it fit, proper and in the interest of justice to remand the case to Tribunal rather than to embark upon the question by ourselves for its decision on merits. ( 13. ) ACCORDINGLY and in view of foregoing discussion, the appeal succeeds and is hereby allowed. Impugned order is set aside. The case is remanded to Tribunal for deciding all these appeals afresh keeping in view the observations made by us supra. ( 13. ) ACCORDINGLY and in view of foregoing discussion, the appeal succeeds and is hereby allowed. Impugned order is set aside. The case is remanded to Tribunal for deciding all these appeals afresh keeping in view the observations made by us supra. It is made clear that Tribunal will be free to decide the appeal on merits on all the issues strictly in accordance with law for examining as to whether AO and CWT (A) were right on their part in making valuation of land in accordance with law. Let this be done within six months from the date of appearance of parties before the Tribunal. Parties to appear before the Tribunal, on 10th July, 2006. No costs.