Route permit value excluded from net wealth where the permit was temporary, restricted, and liable to cancellation.

A route permit under the Motor Vehicles Act, 1939 was treated as an interest in property available for a period not exceeding six years from vesting and therefore fell outside the definition of "assets" in section 2(e)(v) of the Wealth-tax Act, 1957. Because the permit was of limited duration, non-transferable except with permission, and liable to cancellation, its value could not be included in the assessee's net wealth. The exclusion of the route permit value from assessable wealth was upheld in favour of the assessee.

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Issues: Whether the value of a route permit could be excluded from the assessee's net wealth as an interest in property not falling within the definition of "assets" under section 2(e)(v) of the Wealth-tax Act, 1957.

Analysis: Section 2(e)(v) excluded from the term "assets" any interest in property available to an assessee for a period not exceeding six years from the date the interest vested in the assessee. The route permit was governed by the Motor Vehicles Act, 1939, under which its duration was between three and five years, it was non-transferable except with permission, and it was liable to cancellation. On that basis, the interest represented by the permit could not be treated as an asset liable to wealth-tax inclusion.

Conclusion: The exclusion of the route permit value from the assessable wealth was in law and is upheld in favour of the assessee.

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