Wealth-tax meaning of "belong to" excludes properties in possession without registered conveyance when ownership is not formally transferred.

For wealth-tax purposes, the expression "belong to" in section 2(m) focuses on dominion and lawful control, not merely on formal conveyance of title. Where consideration had been paid and possession delivered, the absence of a registered conveyance deed did not by itself mean the immovable property belonged to the assessee. Applying that construction, the Tribunal held that the flat, Okhla plot and hotel site were not includible in net wealth because they did not belong to the assessee in the statutory sense. The matter was treated as one of evidence and the legal meaning of "belonging to", and no substantial question of law arose.

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Issues: Whether immovable properties for which consideration had been paid and possession handed over, but no registered conveyance had been executed, could be said to "belong to" the assessee within the meaning of section 2(m) of the Wealth-tax Act, 1957 and be included in net wealth.

Analysis: The governing test under section 2(m) is whether the asset belongs to the assessee, not merely whether title has been formally conveyed. The Court relied on the distinction between ownership and belonging, and noted that in wealth-tax matters the statutory expression focuses on dominion and lawful control over the asset. Applying that principle, and following the Supreme Court's treatment of similar facts, the Tribunal found that the flat, the Okhla plot and the hotel site did not belong to the assessee merely because conveyance deeds had not been executed in his favour. Those findings were based on appreciation of the evidence and the legal meaning of "belonging to" under the Act.

Conclusion: The properties were not includible in the assessee's net wealth under section 2(m) of the Wealth-tax Act, 1957, and the appeal raised no substantial question of law.

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