These appeals have been filed by assessee and are directed against consolidated order of AAC dt. 1st Dec., 1986, relating to asst. yrs. 1977-78, 1979-80, 1980-81 and 1981-82. Although many grounds of appeal have been set up by assessee, but at time of hearing, ld. authorised representative of assessee had argued only ground No. 2(a) which relates to nonallowing of 10 per cent deduction for joint ownership and rest of grounds were not pressed. In all appeals, controversy relates to value of immovable property situated at 86/11, Kalpi Road, Kanpur. assessee had brought appeals before AAC against valuation determined by WTO. Valuation Officer was present at time of hearing of appeals before AAC. He gave his working according to which value came to Rs. 48 per sq. yd. in month of Dec., 1976. assessee's representative had agreed to that valuation. However, it was submitted on behalf of assessee that said valuation should remain fixed at least for period of 3 years and valuation officer had agreed to that proposition. In pursuance of such agreement, value of land in question was taken at Rs.48 per sq. yd. For asst. yrs 1977-78 and 1979-80, its value came to Rs.5,16,480. Considering appreciation of 10 per cent in each year, land rate for asst. yrs. 1980-81 and 1981-82 was taken at Rs.64 per sq. yd. according to which value for said years came to Rs. 6,88,640. Against these valuation, assessee claims that 10 per cent deduction should be allowed for joint ownership. ld authorised representative for assessee had contended that there are four coparceners in assessee HUF and, therefore 10 per cent deduction for joint ownership would be reasonable and in conformity with legal principles. In support of that view, he has placed reliance on CWT vs. K.N. Nagabhushana Setty (HUF) (1985) 47 CTR (Kar) 150: (1985) 156 ITR 484 (Kar). It has been contended that in that case also, assessee was HUF and 10 per cent deduction was allowed. That deduction was allowed on principle that there are difficulties inherent in enjoyment of undivided share in property purchased in open market and Courts and text book writers have permitted allowance or deduction book writers have permitted allowance or deduction of at least 10 per cent from estimated value of share. ld. authorised representative of assessee has also filed before us extract of valuation report in case of M/s. Jai Dayal Pyare Lal, HUF, wherein Valuation Officer has mentioned since property is jointly owned by four persons (members of HUF) as such 10 per cent deduction may be allowed for joint ownership. On other hand, ld. Departmental Representative has contended that in HUF, principle of joint ownership cannot be applied inasmuch as entire HUF owns property and it is wealth of HUF which is being assessed. According to him, there is no co-owner in HUF. He has further pointed out that assessee had agreed to rate of Rs.48 per sq. yd. in asst. yr. 1977-78 and as such it should have no grievance. We have given our anxious consideration to rival submissions. It would be appropriate to mention here that any observation by Valuation Officer in case of another assessee can be little assistance to assessee in this case if principle applied in that case is not in conformity with legal principles. That being so, we are of opinion that extract from valuation report filed in case of M/s. Jai Daya Pyare Lal is of no significance. We also feel that assessee does not get any support from case of K.N. Nagabhushana Setty (HUF) (supra). Although assessee in that case was HUF, it does not appear that entire property was owned by HUF. On other hand, it appears that assessee was one of co-owners of property consisting of shop, building and godown with appurtenant land. In case before us, assessee is owner of property in question and is not co-owner. That being distinguishing feature we are of opinion that above cited case is of no help to assessee. joint property must be distinguished from undivided coparcenary interest. essence of coparcenary is unity of ownership. According to true notion of undivided family governed by Mitakshara School of Hindu Law, no individual member of that family, whilst it remains undivided, can predicate, of joint and undivided property, that he or any particular member has definite share, one third or one fourth. His interest is fluctuating interest, capable of being enlarged by deaths in family, and liable to be diminished by births in family. It is only on partition that he becomes entitled to definite share. In case of joint ownership, every co-owner has definite share in property. joint property devolves like joint family property by survivorship. But male issues of joint tenants do not acquire any interest in it by birth. Two complete strangers may be joint family property by survivorship. But male issues of joint tenants do not acquire any interest in it by birth. Two complete strangers may be joint tenants but in no conceivable circumstance could they constitute joint Hindu family or hold property as joint Hindu family fundamental principle of joint Hindu family is tie of sapindaship without which it is impossible to form joint Hindu family. In view of what has been discussed above, appeals are without any merit and are, accordingly, dismissed. *** KRISHNA NAND GARG (HUF) v. WEALTH-TAX OFFICER