Plain meaning in tax law: vacant land was treated as urban land on the valuation date despite later residential construction.

Vacant land purchased shortly before the valuation date remained taxable as urban land because its character had to be determined on that date, not by later construction of a house. The statutory definition was applied according to its plain and unambiguous language, and the plea of residential intention or hardship could not create an exclusion not found in the text. The rule against supplying a casus omissus and the principle that no equity can be imported into a taxing statute were applied. The inclusion of the land in wealth-tax was sustained.

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Issues: Whether vacant land purchased shortly before the valuation date was includible as urban land under the Wealth Tax Act despite subsequent construction of a house.

Analysis: The land was vacant on the valuation date and fell within the definition of urban land. The later construction of a house, or the plea that the land was acquired for residential construction, did not alter its character on the relevant date. The statutory language was held to be clear and unambiguous, leaving no scope to read into it an exclusion based on hardship or subsequent events. The rule against supplying a casus omissus was applied, along with the principle that in a taxing statute there is no equity and nothing can be implied beyond the words used.

Conclusion: The vacant land was correctly treated as taxable urban land, and the addition was sustained.

Ratio Decidendi: A taxing provision must be applied according to its plain language, and a vacant plot falling within the statutory definition remains taxable on the valuation date notwithstanding later construction or equitable hardship.

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