Hindu Undivided Family status under wealth-tax rules extends to families with female members, not only coparceners.

The higher-rate wealth-tax provision for a specified Hindu undivided family applies where the family consists of one male member and female members, because the Schedule uses the word "member" and not "male member" or "coparcener". A Hindu undivided family need not have two coparceners for tax purposes, and female members can fall within the statutory description. The distinction between coparcenary and Hindu undivided family is material, so the provision cannot be narrowed by reading in a restriction the text does not contain; the assessee's contrary contention was rejected.

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Issues: Whether a Hindu undivided family can be assessed at the higher rate as a specified Hindu undivided family under sub-paragraph (1A) of para. A of Part I of the Schedule to the Wealth-tax Act when the family consists of a sole male member and female members, and whether the word "member" in that provision is confined to coparceners or male members only.

Analysis: The provision uses the expression "member" and not "male member" or "coparcener". A Hindu undivided family is not required to have at least two coparceners for tax purposes, and a female can be a member of such a family. The distinction between a coparcenary and a Hindu undivided family is material, and the existence of female members does not exclude the family from the statutory description. The construction urged for the assessee would improperly read into the Schedule a restriction that is not expressed there.

Conclusion: The higher-rate provision applies to a Hindu undivided family consisting of one male member and female members, and the assessee's contention was rejected.

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