(concurring in part with and dissenting in part from both Justices Ryan and Moody). Our 1974 CAF1 opinion held, inter alia: (1) the assessing agency may consider a number of different value components in determining true cash value, including values of comparable properties and the statutory term "economic income” from the subject property; (2) the statutory term "economic income” equates with "actual” rent, not "market” rent; and (3) since the assessing agency reached true cash value by capitalizing "market” rather than "actual” rent,2 the case must be reversed and remanded "for proceedings consistent with this opinion.”3
Upon remand, the Tax Tribunal used the same income capitalization assessment formula, and, for all the record shows to the contrary, again through ignorance or arrogance capitalized "market” rent instead of "actual” rent. I concur with my Brother Ryan that in so doing the tribunal directly violated our 1974 CAF opinion and the case must be reversed and remanded once again.
However, I dissent from my Brother Ryan’s following statements, pertinent to the tribunal’s response to our remand. His opinion states:_
*485a) "This Court reversed the tax commission and remanded for a determination of true cash value based on actual income.”
b) "We refused to allow the consideration of actual income to be diluted by reference to the potential income of comparable property then, and we do so now.”
c) "The precise error in the tribunal’s calculation of true cash value having been indicated, and the Tax Tribunal having made detailed findings of fact on the expense and capitalization figures to be utilized, the actual per square foot rental value need now only be 'plugged into’ the formula to arrive at projected income.” The fact of the matter is the 1974 CAF opinion stated:
a) "Reversed and remanded to the Tax Tribunal for proceedings consistent with this opinion.”
b & c) "We point out that 'consideration’ of the enumerated factors under MCL 211.27; MSA 7.27 does not require that the taxing authority determine projected income under the income capitalization approach upon any one or all of the enumerated factors ('economic’ or actual income being one of those factors) so long as the valuation comports with the statute’s definition of true cash value as 'usual selling price at the place where the property to which the term is applied shall be at the time of assessment, being the price which could be obtained for the property at private sale, and not at forced or auction sale.’ 'Consideration’ of the various factors may well indicate that the application of some or all enumerated factors is inappropriate.”4
Therefore, on remand, according to our 1974 CAF opinion the assessing agency is not limited to "plugging in actual rent” in the income capitaliza*486tion formula, for under MCL 211.24; MSA 7.24, the assessor is required to reach a particular result, i.e., "cash value”, not apply a specific formula, such as income capitalization. As a consequence, the assessing agency may use any one of a number of accepted formulas so long as it recognizes the various value components set forth in MCL 211.27; MSA 7.27. That section states: "In determining the value the assessor shall also consider * * * present economic income * * *.” Insofar as "economic income” is considered, that term must be interpreted as actual income.
Further, on the second argument of this matter, the import of the requirement of constitutional uniformity was particularly stressed by the assessing agency and considered particularly important by my Brother Moody, with whom I concur on this point. There is no question that the rule of uniformity is of paramount significance in all assessing. But obviously, as my Brother Ryan observed, all property does not require the same assessment because all property is not the same. However, this still leaves the question to be decided, what is the focus of the assessment: a particular lease of significant value, incidentally attached to a piece of property, or, a particular piece of property of significant value, with an unfavorable lease incidentally attached? Obviously, this issue and all the statutory value components must be considered. Importantly, the answers must first come from the assessing agency, MCL 211.24; MSA 7.24, and with rather restricted judicial review.5
*487In conclusion, I would reverse and remand for further proceedings not inconsistent with the 1974 CAF and this opinion.
CAF Investment Co v State Tax Comm, 392 Mich 442; 221 NW2d 588 (1974).
This action was approved by the Tax Tribunal: the Court of Appeals reversed and remanded. CAF Investment Co v Saginaw Twp, 79 Mich App 559; 262 NW2d 863 (1977).
CAF Investment Co v State Tax Comm, supra, 392 Mich 457.
CAF Investment Co v State Tax Comm, supra, 392 Mich 456, fn 6.
Article 6, § 28 of the Michigan Constitution of 1963, speaking to the scope of judicial review of administrative decisions regarding the property tax, states in pertinent part:
"In the absence of fraud, error of law or the adoption of wrong principles, no appeal may be taken to any court from any final agency provided for the administration of property tax laws from any decision relating to valuation or allocation.”
See, also, MCL 211.152; MSA 7.210, citing the above as the stan*487dard of review in individual assessment cases before the State Tax Commission.