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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 ..... 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 No. 607 Angal Bhawan, New Delhi be determi ..... X X X X Extracts X X X X X X X X Extracts X X X X ..... 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. Sawhney (1982) 2 ITD 207 (Del) (SB), the ass ..... X X X X Extracts X X X X X X X X Extracts X X X X ..... 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 that word. In Accordance with the above mea ..... X X X X Extracts X X X X X X X X Extracts X X X X
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