TMI Blog1977 (12) TMI 2X X X X Extracts X X X X X X X X Extracts X X X X ..... "(1) Whether, on the facts and in the circumstances of the case, the Tribunal was justified in holding that section 2(e)(v) of the Wealth-tax Act, 1957, refers to interest in non-agricultural property and that the interest in agricultural land is exempt under section 2(e)(i) of the Wealth-tax Act ? (2) Whether, on the facts and in the circumstances of the case, the Income-tax Appellate Tribuna ..... X X X X Extracts X X X X X X X X Extracts X X X X ..... the W.T. Act, 1957, gives an inclusive definition of the term " asset " as follows : " 2. Definitions.--In this Act, unless the context otherwise requires,--... (e) 'assets' includes property of every description, movable or immovable, but does not include-- (i) agricultural land and growing crops, grass or standing trees on such land;... " It will thus be seen that agricultural land h ..... X X X X Extracts X X X X X X X X Extracts X X X X ..... see for a period not exceeding six years from the date the interest vests in the assessee ". The argument was that since the sayar income was a constant source, it is a case where the income accrues for a period exceeding six years. This is an argument which can be based only upon a certain knowledge of what the future may have in store. It is not possible to say that in future sayar income will n ..... X X X X Extracts X X X X X X X X Extracts X X X X
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