Wealth-tax exemption for agricultural equipment depends on the assessee's own use, so a hired-out combine harvester was taxable.

A combine harvester owned by the assessee and given on hire did not qualify for exemption under section 5(1)(ix) of the Wealth-tax Act because the statutory condition requires the assessee's own use of the tool, implement or equipment for cultivation, maintenance or harvesting activities. Hiring the machine out meant the assessee used it for the business of hiring, not for agricultural operations, and any agricultural use by the hirer could not satisfy the provision. Its value was therefore includible in the assessee's net wealth.

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Issues: Whether the value of a combine harvester machine owned by the assessee and given on hire was exempt under section 5(1)(ix) of the Wealth-tax Act from inclusion in the assessee's net wealth.

Analysis: The exemption under section 5(1)(ix) applies only to tools, implements and equipment used by the assessee for cultivation, conservation, improvement or maintenance of agricultural land, or for raising or harvesting agricultural or horticultural produce. The decisive requirement is the assessee's own use of the asset for the specified agricultural purposes. A machine hired out by the assessee is used by the assessee for the purpose of hiring, not for harvesting. Any agricultural use made by the hirer does not satisfy the statutory condition, because the use must be attributable to the assessee.

Conclusion: The combine harvester was not exempt under section 5(1)(ix) of the Wealth-tax Act and its value was includible in the assessee's net wealth.

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