COMMISSIONER OF WEALTH TAX, WEST BENGAL vs BISHWANATH CHATTERJEE AND OTHERS

The Supreme Court held that under the Wealth Tax Act, properties inherited by individuals governed by the Dayabhaga School of Hindu Law are assessable as Hindu Undivided Family (HUF) property until partitioned. The Court clarified that in Dayabhaga, ownership is defined at the moment of inheritance, creating fractional ownership among heirs, contrasting with the Mitakshara School's concept of joint ownership. The appeal was dismissed, affirming the High Court's ruling that wealth tax liability arises from ownership, not mere possession, under Section 3 of the Wealth Tax Act.