two fold objections of Revenue are as follows: "On facts and in circumstances of case AAC has erred in directing ITO: (1) to value flat at Rs. 1,84,180 in terms of r. 1-BB as against Rs. 2,69,736 adopted by WTO, (2) to allow deduction under s. 5(i)(iv) in respect of flat. After hearing Shri S. K. Bansal. ld. Departmental Representative it appears to us that there is no substance in any one of contentions raised in this appeals. As far as finding of AAC that valuation of assessee s flat bearing No. 607 Angal Bhawan, New Delhi be determined in accordance with r. 1BB of WT Rules is concerned, we find that it was in accordance with decision of Special Bench of ITAT in case of Biju Patnaik vs. WTO (1981) 12 TTJ (Del) 25: (1982) 1 SOT 623 (Del). Since we are in respectful agreement with above mentioned Special Bench decision, we would uphold order of AAC which was in accordance with decision. Ground No. 1 in Departmental appeal, therefore, fails. It is next contended that AAC of WT Act had no justification in holding that assessee was entitled to deduction of Rs. 1 lakh under provisions of s. (5)(1)(iv) of WT Act, 1957 in respect of value of its above mentioned flat which was not registered in its name. In support of these contentions reliance has been placed by Departmental Representative on decisions of 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). It appears to us that in view of Special Bench decision of ITAT in case of CIT vs. R. K. Sawhney (1982) 2 ITD 207 (Del) (SB), assessee was entitled to exemption under s. 5(1)(iv) of WT Act. Apart form support that we derive from Special Bench decision of ITAT, we are of view that expression assets as defined in WT Act is of very wide description and includes properties movable and immovable of all kinds. According to us such definition would not only embrace within itself movable or immovable property but also include any interest in property. Since assessee had bundle of proprietary rights in aforementioned property it cannot be said that asset enjoyed by it was not entitled to exemption within meaning of s. 5(1)(iv). It has been held by their Lordships of Hon ble Supreme Court of India in case of Raja Mohd. Amjir Ahmad Khan AIR 1965 SC 1923 that word belonging could signify possession of interest which is lees than that of full ownership. Their Lordships observed as follows: "Though word belonging is capable of denoting absolute title, it is nevertheless not confined to connoting that sense. Even possession of interest less than that of full ownership could be signified by that word. In Accordance with above meaning given by Hon ble Supreme Court to word belonging and having regard to decision of Special Bench of ITAT in case of R. K. Sawhney and various other decisions where word belonging has been interpreted by Hon ble Courts and which decisions are reported as CED vs. Estates of Late Sanka Simhachalam (1975) 99 ITR 370 (AP), CED vs. Jyotimoy Raha (1978) 112 ITR 969 (Cal), CED vs. Estate of Late R. Krishnamachari 1978 CTR (Mad) 125: (1978) 113 ITR 200 (Mad) and CWT vs. K. Ramachandra Chettiar (1983) 35 CTR (Mad) 126: (1983) 141 ITR 771 (Mad) we would hold that appellant was entitled to exemption under s. 5(1)(iv) in respect of his flat at 607 Ansal Bhanwan. decisions cited by Shri Bansal. ld. Departmental Representative are given entirely on different facts and would, therefore, be inapplicable in context of present case. In conclusion, Departmental appeal fails and is hereby rejected. *** WEALTH-TAX OFFICER v. J.P. AGARWAL (HUF)