Beneficial ownership alone did not secure wealth-tax exemption for savings certificates not held in the assessee's name.

The exemption for savings certificates under section 5(1)(xvi) of the Wealth-tax Act was confined to certificates actually held by the assessee in his own name. Although the expression "belonging to the assessee" in the definition of net wealth could extend to beneficial ownership, the different wording used in the exemption provision showed a deliberate legislative distinction. Read with the certificate scheme and the limit on individual holdings, certificates standing in nominees' names but beneficially owned by the assessee were not covered by the exemption and remained part of taxable net wealth.

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Issues: Whether savings certificates not standing in the assessee's name, but beneficially owned by the assessee, were exempt from wealth-tax under section 5(1)(xvi) of the Wealth-tax Act, 1957.

Analysis: The expression "belonging to the assessee" in the definition of net wealth and assets was treated as wide enough to cover property in which the assessee had proprietary or beneficial ownership, even if the property stood in another's name. However, the exemption in section 5(1)(xvi) used the different expression "held by the assessee". The use of different language in the same Act indicated a deliberate legislative distinction. Read in the context of the certificate scheme and the limit on individual holdings, the exemption was confined to certificates actually held in the assessee's name, and not to certificates merely beneficially owned by him but registered in the names of nominees.

Conclusion: The certificates not standing in the assessee's name were not exempt under section 5(1)(xvi) and were includible in the taxable net wealth; the question was answered in the negative.

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