Hegde, J.

1. This is a reference under section 27(3) of the Wealth-tax Act, 1957, to be hereinafter referred to as the "Act". Two questions referred to this court for its opinion are : (1) Whether, on the facts and in the circumstances of the case, the Tribunal was justified in ignoring the value of the land surrounding the buildings in valuing the properties Nos. 1 and 2 ?; l and (2) Whether an asset such as land acquires value only when there is an intention to sell ? The facts of the case are fully set out in the statement of the case submitted. Hence, we shall quote the same.

[The learned judge set out the statement of case which ran as follows :

The High Court of Mysore at Bangalore by their order dated 1st October, 1963, in Civil Petition No. 87 of 1963 have directed the Tribunal to submit the following two questions of law along with a statement of the case to the High Court. In compliance with the said order of the High Court, we submit the following two questions of law under section 27(3) of the Wealth-tax Act along with the agreed statement of the case :

"(i) Whether, on the facts and in the circumstances of the case, the Tribunal was justified in ignoring the value