In support of the accountable person 's appeal Dr. Ghosh submitted: a) First, that, on a proper construction of the two deeds, what must be held to constitute their subject matter are only the shares in the properties corresponding to the interests intended for the benefit of the deities and the charities; and that the interest in the property correspond 278 ing to the benefit retained by the settlor was not the subject matter of the disposition at all; b) Secondly, that, even if both the documents might admit of being called "settlements" in a wider sense the properties dealt with thereunder were not "Settled Property" within the meaning of Section 2(19) as there was no in tervening limited interest before a final vestiture of the ownership; and c) Thirdly, that, at all events, what must be held to attract and fall within the mischief of Section 12(1) and be deemed to pass on death would only be the value of such share as corresponds or referable, to the quantum of interest so reserved by the settlor namely 5/16th share in the properties covered by the first document and 1/2 share in the properties comprised in the second document and not the entire value of all the properties.