Judgment

A.K. Sikri, J.

In these cases, we are concerned with the interpretation that is to be accorded to the provisions of Explanation 1(b) to Section 2(ea)(v) of the Wealth Tax Act, 1957 (hereinafter referred to as the 'Act'). This Explanation defines 'Urban Land'. Urban land is exigible to wealth tax under the aforesaid Act. However, the definition of 'urban land' in explanation 1(b) excludes certain category of lands. As per Explanation 1(b) to Section 2(ea)(v), 'urban land' to mean land situate – but does not includes:-

(i) land classified as 'agricultural land' in the records of the Government and used for agricultural purposes or land on which construction of a building is not permissible under any law for the time being in force in the area in which such land is situated; or

(ii) the land occupied by any building which has been constructed with the approval of the appropriate authority; or

(iii) any unused land held by the assessee for industrial purposes for a period of two years from the date of its acquisition by him; or

(iv) any land held by the assessee as 'stock-in-trade' for a period of ten years from the date of its acquisition.

2. To put it pithily, what calls for interp