Tribunal, Allahabad has referred following questions of law under s. 27(1) of WT Act, 1957 (hereinafter referred to as "the Act") for opinion to this Court: "1. Whether on facts and in circumstances of case, Tribunal was justified in applying income capitalisation method on average profit for three years in valuing cold storage in dispute and also holding that book value of assets is to be taken into consideration and capital in firm is not to be added back separately? Whether on facts and in circumstances of case, Tribunal w s justified in concluding that cold storage is industrial undertaking within meaning of s. 5(1) of WT Act, 1957 and thereby allowing assessee s claim for deduction under said provisions?" It may be mentioned here that Tribunal by consolidated order dt. 19th Aug., 1992 had decided nine reference applications filed by five assessees who were partners, in their representative capacity in firm M/s Vishwanath Cold Storage & Industries, Jaunpur, relating to asst. yr. 1985-86 in case of Sri Chhotey Lal HUF, Jaunpur, and in respect of asst. yrs. 1985-86 and 1986-87 of Sri Bankey Lal HUF, Sri Chhagan Lal HUF, Sri Lalji HUF and Sri Bhagwati Seth HUF of Jaunpur. Briefly stated, facts giving rise to present reference are as follows: All respondent-assessees filed their return of wealth for assessment years in question in which they had disclosed interest in firm M / s Vishwanath Cold Storage & Industries, Jaunpur by taking three years average profit and applying income capitalisation method. AO had determined interest separately by adopting land and building method and value of plant and machinery at market rate. According to AO, s. 4(1)(b) of Act provides manner in which interest of assessees as partners of firm or member of AOP (not being co-operative society) shall be determined. As per WT Rules, interest in partnership is to be determined under r. 2. AO consequently added excess valuation to wealth of assessees. assessees further claimed exemption under s. 5(1)(xxxii) of Act in respect of investment made in cold storage, which exemption was disallowed by AO. However, in appeals, CWT(A) by following order passed by Tribunal in respect of asst. yr. 1984-85, upheld contention of assessees. He directed that value of interest be determined on basis of income capitalisation method. appeals of Revenue before Tribunal had failed. We have heard learned counsel for parties. So far as first question is concerned, we find that this Court in WT Ref. No. 39 of 1985, CWT vs. Bankey Lal decided on 21st Oct., 2005 [reported at (2006) 200 CTR (All) 62 Ed.] has answered similar question in respect of determination of partner s interest in firm M/s Vishwanath Cold Storage & Industries, Jaunpur, in favour of Revenue and against assessee. Thus, first question is answered in negative, i.e., in favour of Revenue and against assessee. So far as second question is concerned, we find that apex Court in case of Delhi Cold Storage (P) Ltd. vs. CIT (1991) 98 CTR (SC) 165: (1991) 191 ITR 656 (SC) has held that cold storage was not industrial undertaking as in cold storage article or goods is neither produced nor processed. It is not entitled for investment allowance. Similar consideration would also be applicable for considering as to whether cold storage is industrial undertaking or not under provisions of s. 5(1)(xxxii) of Act. In this view of matter, we are of considered opinion that investment in cold storage is not entitled to deduction (sic exemption) under s. 5(1)(xxxii) of Act as cold storage is not industrial undertaking. second question, therefore, is also answered in negative, i.e., in favour of Revenue and against assessee. There shall be no order as to costs. *** Commissioner of Wealth-tax v. Chhotey Lal