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TMI Blog1985 (12) TMI 111X X X X Extracts X X X X X X X X Extracts X X X X ..... the flat at Rs. 1,84,180 in terms of r. 1-BB as against Rs. 2,69,736 adopted by the WTO, (2) to allow deduction under s. 5(i)(iv) in respect of flat. 2. After hearing Shri S. K. Bansal. ld. Departmental Representative it appears to us that there is no substance in any one of the contentions raised in this appeals. As far as the finding of the AAC that the valuation of the assessee's flat bearing ..... X X X X Extracts X X X X X X X X Extracts X X X X ..... these contentions reliance has been placed by the Departmental Representative on the decisions of the Hon'ble Delhi High Court reported in CIT vs. Hans Raj Gupta (182) 27 CTR (Del) 92 : (1982) 137 ITR 195 (Del) and CWT vs. Meatles (P) Ltd. (1984) 40 CTR 281 (Del) : (1985) 153 ITR 201 (Del). 4. It appears to us that in view of the Special Bench decision of the ITAT in the case of CIT vs. R. K. Saw ..... X X X X Extracts X X X X X X X X Extracts X X X X ..... . Amjir Ahmad Khan AIR 1965 SC 1923 that the word 'belonging' could signify possession of an interest which is lees than that of full ownership. Their Lordships observed as follows: "Though the word 'belonging' is capable of denoting an absolute title, it is nevertheless not confined to connoting that sense. Even possession of an interest less than that of full ownership could be signified by tha ..... X X X X Extracts X X X X X X X X Extracts X X X X
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