Court held that, the scope of remand by the Tribunal to the Wealth-tax Officer was only with respect to the specific question of valuation. At that stage, when the Wealth-tax Officer decided on the valuation, the final report of the Departmental Valuation Officer was not available. The findings rendered by the Wealth-tax Officer could not have been interfered with by the Commissioner (Appeals) who entertained the issue of taxability which had been earlier given up. The circumstances that for later years, the Department did not accept the contentions regarding the non-taxability of assets, per se, could not afford a ground to insist that the remand made by the Tribunal ought to and was enlarged so as to include that ground in the earlier order when it was not agitated. Matter remitted for consideration of issue of valuation. ( AY.1993-94, 1994-95)