Ordinary meaning of "motor car" under wealth-tax law includes a jeep, so the exclusion claim fails.

The expression "motor car" in the wealth-tax provision was construed in its ordinary and commercial sense, and the Court held that a jeep falls within that broad meaning. The absence of a statutory definition did not prevent that construction where the legislative context indicated inclusion of vehicles of that class. On that interpretation, the jeep could not be excluded from the company's wealth-tax computation, and the reference was answered in favour of the Revenue.

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Issues: Whether the expression "motor car" used for the purpose of levy of wealth-tax on a company includes a jeep.

Analysis: The expression "motor car" was construed in its ordinary and commercial sense. The Court accepted the view that a jeep is a sturdy motor car and that, in the context of the relevant wealth-tax provision, the term was intended to cover vehicles falling within the broad sense of motor cars. The Court also approved the view that the absence of a statutory definition did not prevent such a construction.

Conclusion: A jeep is included within the expression "motor car" for the purpose of the wealth-tax levy, and the question was answered in favour of the Revenue.

Final Conclusion: The reference was disposed of by holding that the assessee was not entitled to exclusion of jeep from the wealth-tax computation under the relevant provision.

Ratio Decidendi: In fiscal interpretation, where a term is used without a restrictive statutory definition, it may be given its ordinary and broad commercial meaning if the statutory context indicates inclusion of that class of vehicle.

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