Registered conveyance required for wealth-tax ownership; cinema building excluded from assessee's net wealth.

Wealth-tax liability depended on whether the property belonged to the assessee on the valuation date. In the absence of a registered sale deed or executed conveyance, ownership did not pass merely because the assessee was in possession, had paid consideration in advance, or enjoyed income from the cinema building. On that basis, the building continued to belong to the transferor and could not be included in the assessee's net wealth. The deletion of the assessee's share in the cinema building was therefore upheld, and the issue was decided in favour of the assessee and against the Revenue.

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Issues: Whether, for wealth-tax purposes, the assessee could be treated as owner of the cinema building and charged to wealth-tax despite absence of a registered conveyance deed.

Analysis: The liability to wealth-tax depends on the property belonging to the assessee on the valuation date. In the absence of a registered sale deed or executed conveyance, ownership does not pass merely because the assessee was in possession, had paid consideration in advance, or enjoyed income from the property. Applying this principle, the cinema building remained owned by the transferor and could not be included in the assessee's wealth.

Conclusion: The deletion of the assessee's share in the cinema building was justified, and the question was answered in favour of the assessee and against the Revenue.

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