Allowing the appeal of the revenue the Court held that; the words “belonging to” which determine the basis of levy and attract the charge of wealth-tax under the Wealth-tax Act, 1957 are of wider import than the narrower concept of “ownership” of the assets which is rigid and narrower in its scope than the words “belonging to”. The words “belonging to” may include within their ambit, the concept of “ownership” also, but the converse may not be always true. The “ownership” of a property continues to be with the owner, even if the property is under a charge or even litigation about title and possession and such “ownership” is not lost merely because of such charge over the property. The word “owner” or “ownership” itself is not defined in the definition clause of the Wealth-tax Act, 1957. The intention of the Legislature is, to throw the tax net of the wealth-tax a little wider and not to cover only “owners” of the assets stricto sensu. Accordingly on facts though litigation is pending regarding the ownership of land, the possession is with the assessee, hence includible in net wealth.  Court also held that protective assessment of Person in possession of land is held to be valid and Tribunal was not justified in setting aside the protective assessment made by the assessing authority. (AY. 1999-2000 to 2004 -05)