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TMI Blog1980 (3) TMI 135X X X X Extracts X X X X X X X X Extracts X X X X ..... the sake of convenience. 2. The sole controversy which arises in these appeals is with regard to the inclusion in the assessments of the value of three immovable properties, Canara Club, Bombay, Cabins and Minto Guest House, Bombay, at the total figure of Rs.1,17,000. The WTO found that these properties were taken by the assessee on rent and had been further sub-let by him at a much higher rent. ..... X X X X Extracts X X X X X X X X Extracts X X X X ..... Club Property, Rs. 7,000 as the value of the Cabins and Rs. 60,000 as the value of Minto Guest House. 3. The assessee appealed to the AAC before whom written argument was filed. It was urged that the assessee had no interest in the said properties and that he had merely sub-let these properties to certain parties in Bombay. The properties in question, it was pointed out, were not the properties ..... X X X X Extracts X X X X X X X X Extracts X X X X ..... roperties, these could not have been sub-let. Referring to s. 2(e) of the WT Act it was urged that the definition of the term 'property' was of the widest amplitude and included interest in property of every description. The WTO, it was urged, had rightly included the amount of Rs. 1,17,000 in the assessment. The learned counsel for the assessee, on the other hand, relied upon the order of the lea ..... X X X X Extracts X X X X X X X X Extracts X X X X ..... ssee had held the properties in question on lease for a specified period. In that case the interest of the assessee in the properties could have been valued and included in the assessments. But where a property is held by an assessee on monthly tenancy, it cannot be said that the assessee has any interest in the property in terms of s. 2(e) of the WT Act which could be valued and assessed to tax. ..... X X X X Extracts X X X X X X X X Extracts X X X X
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