1994 (7) TMI 19

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..... is common, they are disposed of by this judgment. At the instance of Revenue, the Income-tax Appellate Tribunal has referred the following question of law arising out of its order dated September 1, 1986, in relation to the assessment years 1973-74 to 1979-80 under section 27(1) of the Wealth-tax Act, 1957: " Whether, on the facts and in the circumstances of the case, the Income-tax Appellate T .....

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..... ssments were made in the hands of the assessee on the protective basis and it was observed that, if the High Court decides that the property belongs to Shri N. K. Sanghi, the protective assessment will be modified accordingly. In the income-tax proceedings, it was held that the property of the cinema building is owned by Shri N. K. Sanghi. It was on that basis, that the Tribunal came to the conclu .....

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..... n or joint possession. In view of the above decision, since in the present case the property, i.e., the cinema building, is owned by Sanghi Brothers and the deed of conveyance was not executed or registered, the assessee cannot be made liable for wealth-tax. Therefore, we are of the opinion that the Income-tax Appellate Tribunal was justified in deleting the share of the assessee in the cinema bu .....

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