Net wealth inclusion depends on ownership on valuation date; title to immovable property passed only after registered conveyance.

Immovable property is includible in net wealth only if it belongs to the assessee on the valuation date. Mere payment of consideration, delivery of possession, or a recital giving ownership an earlier date does not itself establish that title passed before execution and registration of the conveyance deed. A registered instrument affecting immovable property cannot operate before the deed comes into existence. Because both execution and registration occurred after the valuation date, the industrial plot was not owned on that date and was excluded from net wealth; the addition was deleted.

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Issues: Whether the industrial plot could be included in the assessee-company's net wealth on the valuation date when the conveyance deed had been executed and registered only after that date.

Analysis: For an immovable property to be included in net wealth, it must belong to the assessee on the valuation date. The mere payment of consideration, delivery of possession, or recital in the document that ownership related back to an earlier date did not by itself establish that title had passed before execution and registration of the conveyance deed. Under the Registration Act, a compulsorily registrable instrument affecting immovable property operates from the time it would have operated if registration had not been required, but the registered instrument cannot operate before the deed itself comes into existence. On the facts, both execution and registration occurred after the valuation date.

Conclusion: The plot did not belong to the assessee on the valuation date and could not be included in its net wealth; the addition was deleted in favour of the assessee.

Ratio Decidendi: Property is includible in net wealth only when it belongs to the assessee on the valuation date, and a transfer of immovable property by registered conveyance is not completed for that purpose until the conveyance deed comes into existence and is registered.

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