Separate plot holdings cannot be clubbed to deny wealth-tax exemption absent statutory deeming fiction or approved amalgamation.

Separately purchased plots held by co-purchasers could not be clubbed to deny exemption under section 5(vi) of the Wealth Tax Act where no sanctioned amalgamation or town-planning approval existed. The assessee's share in the plots did not exceed the statutory 500 sq. mtrs. threshold, and the provision contained no deeming fiction authorising aggregation of distinct holdings to cross that limit. Applying strict construction of taxing provisions, any doubt had to be resolved in favour of the taxpayer. The assessee was therefore entitled to exemption and relief under section 5(vi).

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Issues: Whether two separately purchased plots could be clubbed to deny exemption under section 5(vi) of the Wealth Tax Act, 1961 and whether the assessee's share in those plots was exigible to wealth tax.

Analysis: The assessee and his wife were co-purchasers of the two plots, and the assessee's share did not exceed the statutory limit of 500 sq. mtrs. The record did not show any clubbing of the plots by sanctioned amalgamation or town-planning approval. Section 5(vi) contains no deeming fiction permitting clubbing of separately held plots to cross the threshold limit. A taxing provision must be strictly construed, and any doubt in its application must go in favour of the taxpayer.

Conclusion: The two plots could not be clubbed for denying exemption, and the assessee was entitled to relief under section 5(vi). The issue was decided in favour of the assessee.

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