These appeals by revenue and cross-objections by assessee are directed against two orders of AAC dated 7-11-1985 and 11-11-1985 respectively relating to asstt. years 1979-80 and 1980-81. grievance of revenue is that he erred in law in directing Wealth-tax Officer to allow deduction under section 5(1)(iv) of Wealth-tax Act. This in nutshell was argument in chief by revenue. 2. On other hand, ld. counsel for assessee supported orders of AAC and proceeded to further make his submissions as under. 3. It was submitted by him that assessee is one of parties who contributed money to put up structure, known as 'Kailash Building', on piece of land and thereafter became entitled to possession, use, occupation and right of enjoyment of flat therein. Therefore, in view of Special Judgement of Tribunal in case of ITO v. R.K. Sawhney [1982] 2 ITD 207 (Delhi) (SB), assessee for purpose of Wealth-tax Act which includes exemption under section 5(1)(iv), should be considered as person to whom assets in form of flat in question belongs. 4. Amplifying this argument, learned counsel for assessee submitted that even judgment of Supreme Court in case of Nawab Sir Mir Osman Ali Khan v. CWT [1986] 162 ITR 888 has not made any difference. In this regard, he examined judgment reported at Nawab Sir Mir Osman Ali Khan's case (supra) and contended that careful reading of judgment will show that Hon'ble Supreme Court has not made any observation about earlier judgment of Supreme Court in case of Raja Mohammad Amir Ahmad Khan v. Municipal Board of Sitapur AIR 1965 SC 1923 and that judgment being judgment of Supreme Court constituted by larger Bench of three judges, should, in view of provisions of article 141 of Constitution of India, have precedence over judgment of Supreme Court in Nawab Sir Mir Osman Ali Khan's case (supra). 5. For this proposition he relied upon following judgments: 1. Ganapati Sitaram Balvalkar v. Waman Shripad Mage AIR 1981 SC 1956. 2. State of U.P. v. Ram Chandra Trivedi AIR 1976 SC 2547. 3. Ghansham Singh v. CIT [1983] 141 ITR 601 (Mad.). 4. CIT v. Sriram Agrawal [1986] 161 ITR 302 (Pat.). pp, 309. 6. Relying upon judgment of Madras High Court in case of CIT v . Ramakrishna & Sons (P.) Ltd. [1982] 135 ITR 56, it was submitted that Hon'ble Supreme Court while delivering judgment in case of Nawab Sir Mir Osman Ali Khan (supra), merely referred to and recorded judgment in case of Raja Mohammad Amir Ahmad Khan (supra) and this in no way can be said to be consideration of that judgment by Supreme Court because Hon'ble Supreme Court has not in judgment at Nawab Sir Mir Osman Ali Khan's case (supra) given any indication, whether that judgment is right or wrong. 7. word 'belonging to' has to be interpreted, it was contended by learned counsel, in context in which it appears and as those concerned with it understand it. It was submitted that if words 'belonging to' are to be interpreted in manner so as to disentitle assessee for exemption under section 5(1)(iv) of Act, then same words 'belonging to' cannot be interpreted so as to bring assets as one of items of net wealth in hands of assessee for purpose of taxation under section 2(m) of WT Act. For this reliance was placed upon judgment of Supreme Court in case of CIT v. B.C. Srinivasa Setty [1981] 128 ITR 294 and Ramesh Chandra Chandiok v. Chunni Lal Sabharwal AIR 1971 SC 1238 at 1243. It was emphasized that said asset cannot even be deemed wealth of assessee in view of ratio decidendi of judgment of Andhra Pradesh High Court, CED v. Estate of Late Sanka Simhachalam [1975] 99 ITR 370 PP 371. At this stage, it was pointed out that Andhra Pradesh High Court has in this judgment considered and followed Supreme Court judgment in case of Raja Mohammad Amir Ahmed Khan (supra). 8. Referring to provisions contained in section 2(e)(v) of Wealth-tax Act, learned counsel for assessee contended that thereunder asset h s been defined as including any interest in property where interest is available to assessee for period exceeding six years from date interest vests in assessee. From this it was projected that right, title and interest of assessee in flat is on better footing and, therefore, that flat should be considered as asset belonging to assessee and as such, assessee is entitled to exemption under section 5(1)(iv), which was rightly granted by AAC. 9. Relying upon circular of Central Board of Direct Taxes being Cir. No. 330, dated 6th March, 1982 at 135 ITR 14 (St.) on provisions of estate duty exemption under section 33(1)(n), it was pointed out that Board has recognized interest less than ownership in property as asset belonging to assessee. In this view of matter, same authority cannot argue that where assessee has right, title and interest and is enjoying property and has right of allowing tenancy, such property does not belong to assessee for purpose of section 5(1)(iv) exemption under Wealth-tax Act. He emphasised that in interpretation of circulars such interpretation be adopted, which is in favour of assessee. He relied upon judgment of Patna High Court in case of Sriram Agrawal (supra). 10. Lastly, he contended that if at all what has been stated above, we consider it as giving rise to situation where on interpretation of previous fiscal statute, two reasonable views are possible, then in view of following judgments of Supreme Court, view that favours subject should be adopted: 60 ITR 342 (sic), CIT v. Kulu Valley Transport Co. (P.) Ltd. [1970] 77 ITR 518, CIT v. Madho Pd. Jatia [1976] 105 ITR 179 and Vrindavan Goverdhan Lal Pittie v. Union of India [1986] 160 ITR 318. 11. learned departmental representative in rejoinder, at very outset submitted that there is no scope for arguments of type projected by ld. counsel for assessee, if judgment of Supreme Court in case of Nawab Sir Mir Osman Ali Khan (supra) referred to (supra) is read in proper perspective considering provisions of statute that Hon'ble Supreme Court was required to interpret. This was argued on basis that issue before Hon'ble Supreme Court was one where property had been sold, vendee had been put in possession, consideration had passed and Court had to decide whether on facts and in circumstances of that case, property still constituted asset within meaning assigned to it under Wealth-tax Act so as to include that asset in net wealth of assessee because it belonged to assessee. In process, Hon'ble Court considered provisions relating to ownership of property and words 'belonging to' in context of issue before it. It is after due consideration, Supreme Court has, inter alia, after consideration of judgment of Raja Mohammad Amir Ahmed Khan (supra) laid down that words 'belonging to' connote ownership only when immovable property is registered in name of vendee. Therefore, there is no room for argument for any one to say that even when property is not registered it belongs to assessee and as consequence, such assessee is entitled to exemption under section 5(1)(iv) of Act. Therefore, ld. AAC erred in holding that assessee was entitled to exemption under section 5(1)(iv). His order be set aside and that of WTO restored in its place. 12. Meeting argument of ld. counsel for assessee, that superstructure of land having been raised by assessee and others with their own capital, structure belongs to assessee, it was argued by ld. DR that assessee is not owner of superstructure in accordance with law but has only right, title and interest, which cannot be considered as immovable property though it is asset within meaning assigned to word "asset" in section 2(e)(v) of Wealth-tax Act, 1957 because asset includes property of every description, both movable and immovable. 13. Adverting to catena of judgments supporting each of arguments made by learned counsel for assessee, it was submitted by ld. DR that these judgments are not relevant because issue in each case cited, was not one that is being agitated before us and that which had travelled before Supreme Court in case of Nawab Sir Mir Osman Ali Khan (supra). 14. above submissions made by rival parties were recorded in open Court in their presence. 15. We have given careful thought to these submissions and have also perused orders of authorities below. first submission by ld. counsel for assessee that assessee and others contributed capital for construction of building which includes flat owned by assessee has been raised for first time before us and requires enquiry on facts. Therefore, this contention at this stage cannot be accepted. Nevertheless, even if building in which flat is occupied by assessee was constructed by contribution of capital by various flat owners, issue still survives as to whether such flat to which assessee has access of possession and enjoyment is "belonging to" assessee within meaning assigned to this phrase in section 2(m) of WT Act, 1957, which defines net wealth. This issue we have to decide on facts and circumstances of case. 16. ld. counsel for assessee was at pains to emphasise that judgment of Hon'ble Supreme Court in case of Nawab Sir Mir Osman Ali Khan (supra) is not applicable to this case now before us because Hon'ble Court has earlier in case of Raja Mohammad Amir Ahmed Khan (supra) taken different view and that judgment being of larger strength of that Court still prevails. To this aspect of issue, we have given very anxious thought. W e have in process very carefully seen authorities cited by him in support of proposition propounded. It appears to us that whereas law declared by Supreme Court is binding on all Courts within territory of India as provided under Art. 141 of Constitution of India, yet, Supreme Court is not bound by its own decisions and may reverse its previous decisions (Dwarkadas Shrinivas v. Sholapur Spg. & Wvg. Co. Ltd. AIR 1954 SC 119, 127). We find that even judgment of Madras High Court in case of Ghansham Singh (supra), relied upon by assessee, does not support him. In this case, Hon'ble Court has held that normally rule is that where law is laid down differently in two different decisions of Supreme Court by Benches of different strengths, decision of larger Bench of Supreme Court should be followed as binding on High Courts. However doctrine that larger Bench of Supreme Court has more authoritative force than smaller Bench is only between cases which yield different ratio decidendi and nowhere one judgment hands down decision while other lays down dictum. Now, when we examine various judgments relied upon by ld. counsel for assessee to make out case that we should ignore judgment of Hon'ble Supreme Court in case of Nawab Sir Mir Osman Ali Khan (supra) and follow judgment of Supreme Court in case of Raja Mohammad Amir Ahmed Khan (supra) have not been shown to come within principles laid down by Madras High Court in case of Ghansham Singh (supra). Coupled with these observations of Madras High Court are powers of Hon'ble Supreme Court to reverse its own decisions. We have, therefore, to see whether Hon'ble Supreme Court's judgment in case of Nawab Sir Mir Osman Ali Khan (supra) has in any manner reversed judgment in case of Raja Mohammad Amir Ahmed Khan (supra). 17. According to ld. counsel for assessee this judgment has not been considered by Hon'ble Supreme Court while deciding case of Nawab Sir Mir Osman Ali Khan (supra), but this does not stand scrutiny. report clearly shows that observations in case of Raja Mohammad Amir Ahmed Khan (supra) have been relied upon by Supreme Court. Apparently, there could not have been reliance for observations of Supreme Court in case of Raja Mohammad Amir Ahmed Khan (supra) without consideration of that judgment by Hon'ble Supreme Court while deciding case of Nawab Sir Mir Osman Ali Khan (supra). We find that at page 897 of Nawab Sir Mir Osman Ali Khan's case (supra), Supreme Court has observed that even in some cases, phrase 'belonging to' is capable of connoting interest, which is less than absolute and perfect legal title. In this regard Hon'ble Court has stated that, in this connection, one should see observations of Supreme Court in Raja Mohammad Amir Ahmed Khan's case (supra). Thereafter, Court has very categorically recorded that, "this Court observed in that case that expression, 'belonging to' no doubt was capable of denoting as absolute title, it was nevertheless not confined connoting that sense. Full possession of interest less than that of full ownership could also be qualified by that expression. Thus, from these observations of Hon'ble Supreme Court, we have no doubt in our mind that submissions made by ld. counsel for assessee, are absolutely untenable and it cannot be said that Hon'ble Supreme Court did not consider their earlier judgment in case of Raja Mohammad Amir Ahmed Khan (supra). Therefore, that judgment is not available to assessee to make claim that he is entitled to exemption under section 5(1)(iv) of WT Act, 1957 in respect of flat which is not yet admittedly registered in name of assessee. Thus, case law relied upon by assessee for proposition that judgment of Supreme Court at Nawab Sir Mir Osman Ali Khan's case (supra) cannot be followed in view of earlier judgment of Supreme Court in case of Raja Mohammad Amir Ahmed Khan (supra) is untenable. case law cited by him, therefore, does not help t h e assessee at all so as to give finding that assessee is entitled to exemption under section 5(1)(iv) because flat belongs to him. 18. However, it is clear that interest of assessee in property in dispute is asset within meaning of section 2(e)(v) of WT Act because assessee is having interest therein for period of exceeding six years. It is noteworthy that definition of asset in clause (e) includes property of every description, movable or immovable. Therefore, interest of assessee has to be determined both in quantum and character. Whereas value of flat cannot be included in net wealth of assessee as if it is immovable property not registered in assessee's name yet value of right, title and interest of assessee therein is to be included in net wealth of assessee and has to be worked out. This has not been done by authorities below at any stage, because, law till then was not as settled as after judgment of Hon'ble Supreme Court in case of Nawab Sir Mir Osman Ali Khan (supra). 19. In so far as contention of ld. counsel for assessee about binding nature of circulars is concerned, it has certain riders. circular must be on subject-matter and there must be no dispute about its applicability. ld. counsel for assessee has cited circular which is about provisions of estate duty. circular, therefore, cannot be said to be straightaway applicable or available for application in interpretation of phrase "belonging to" used in section 2(m) of WT Act. words "belonging to" in section 2(m) of WT Act have been interpreted by Hon'ble Supreme Court in Nawab Sir Mir Osman Ali Khan's case (supra). Therefore, there cannot be any doubt about its interpretation and Board's circular cannot apply even be any doubt about its interpretation and Board's circular cannot apply even if it is directly on issue. 20. ld. counsel for assessee had submitted before us that circulars being issued by CBDT would be binding because it should served s estoppel. However, this does not appear to be supportable proposition. Supreme Court has held that doctrine of "approbate and reprobate" is only species of estoppel; it applies only to conduct of parties but cannot operate against provisions of statute as held in case of CIT v. V.MR.P Firm in [1965] 56 ITR 67. This principle has further been enunciated in case of Bakul Oil Industries v. State of Gujarat [1987] 165 ITR 6 (SC). 21. We have also carefully considered submission of ld. counsel for assessee that in view of settled proposition of law that in interpretation of fiscal statute when two reasonable views are possible, one that favours subject should be adopted. In fact this was what Hon'ble Supreme Court laid down in case of Kulu Valley Transport Co. (P.) Ltd. (supra). Hon'ble Supreme Court has again held in case of CIT v. J.K. Hosiery Factory [1986] 159 ITR 85 that assessee is entitled to interpretation, which is favourable to him in case of doubt. Supreme Court in case of Madho Pd. Jatia (supra) has, however, held that where provisions of taxing statute are clear and unambiguous, full effect must be given to them irrespective of any consideration of equity. Court has further held that where, however, provisions are couched in language, which is not free from ambiguity and merits two interpretations, view which is favourable to citizen should be adopted. fact that such interpretation is also in consonance with ordinary notions of equity and fairness would fortify Court in adopting such course. With profound respect, we are of opinion that in order to judge whether provision is clear and unambiguous or merits two interpretations, there is no Court higher than Supreme Court. Therefore, when question, whether, on facts and in circumstances of case, properties in respect of which registered sale deeds had not been executed, but consideration had been received, belonged to assessee-vendor for purpose of inclusion in his net wealth within meaning of section 2(m) of Wealth-tax Act, 1957, came before Hon'ble Supreme Court in case of Nawab Sir Mir Osman Ali Khan (supra), Court answered that question considering all principles of construction of fiscal statutes. judgment given by Hon'ble Court is clear that value of such properties was to be included in net wealth of assessee-vendor for purpose of asstt. to wealth-tax as they were assets belonging to him within meaning of section 2(m) of WT Act until registration took place. Such judgment, we are duty bound to follow respectfully. We cannot enter upon controversy whether we still have to find out which is reasonable view favourable to assessee. In our considered opinion, principle of two reasonable views is only for subordinate Courts because when Hon'ble Supreme Court decides case o n interpretation of fiscal statute, its judgment is birding on all subordinate Courts and is final as law of land. type of contentions raised on behalf of assessee, therefore, cannot be entertained. These are rejected. 22. However, this leaves us with issue still open for determination. We have observed supra that Wealth-tax Officer proceeded to add value of flat and did not give assessee exemption under section 5(1)(iv) of Wealth-tax Act. But value of impugned property as such cannot be included because it does not 'belong to' assessee; there being no valid registration so far. However, at same time, value of right, title and interest of assessee in said property deserves inclusion in net wealth of assessee. From this angle issue has not been examined at all. In view of what is stated above, we set aside orders of authorities below and restore issue to WTO with directions that he should decide it afresh in accordance with law after affording reasonable opportunity of being heard to assessee and after taking into consideration judgment of Supreme Court in case of Nawab Sir Mir Osman Ali Khan (supra) and any other judge-made or statutory law that may be available to him at time he makes de novo assessment. We order accordingly. 23. In view of what is stated above, appeals of revenue are considered as allowed for statistics. We, however, find that cross objections filed by assessee are out of time by 309 days. There is no reasonable and sufficient cause to explain this delay. ld. counsel for assessee submitted that in arguments in appeal of revenue he has dealt with all aspects that in arguments in appeal of revenue he has dealt with all aspects of case and would not like to press for cross objections. However, we reject cross objections as barred by limitation. appeals of revenue considered as allowed for statistics and cross objections dismissed. *** WEALTH-TAX OFFICER v. T.S. BEDI & FAMILY (HUF)