Commercial property in construction may still qualify as a business asset for wealth-tax exemption under the governing High Court ruling.

Land on which a commercial building is under construction may still be treated as commercial property for wealth-tax purposes, because the construction activity changes the character of the asset even before completion. Applying the controlling jurisdictional High Court ruling, the Tribunal accepted that exemption is not confined to land with a completed building by the end of the relevant previous year. The stated effect was that the property qualified as a business asset for wealth-tax exemption, and the Revenue's objection based on incomplete construction was rejected.

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Issues: Whether land with a building under construction could be treated as a commercial property or business asset eligible for wealth-tax exemption.

Analysis: The Revenue's objection was that exemption was unavailable unless construction of the building was complete by the end of the relevant previous year. The controlling jurisdictional High Court ruling was applied, which held that even a building under construction alters the nature of the land and renders it a commercial property entitled to wealth-tax exemption.

Conclusion: The exemption claim was accepted and the Revenue's appeals failed.

Ratio Decidendi: For wealth-tax purposes, land on which construction of a commercial building is in progress may still retain the character of a commercial property and qualify for exemption as a business asset.

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