Urban land retained by company remains taxable where legal title and statutory exclusion are absent.

Vacant urban land remained assessable to wealth-tax because the assessee-company retained legal title and control over alienation, despite placing the land at the disposal of a welfare body for recreational use. Permissive occupation did not create adverse possession, and continued liability for municipal levies supported ownership with the assessee. Proceedings under the Urban Land Ceiling law did not vest the property in Government, as no vesting notification had been published. The land also did not qualify for any statutory exclusion from the definition of urban land, including use for employee welfare. The company's objections were rejected and the land was held chargeable to wealth-tax.

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Issues: Whether the vacant land at Banjara Hills, Hyderabad, was assessable to wealth-tax in the hands of the assessee-company.

Analysis: The land had been placed at the disposal of Asbestos Centre for welfare and recreational use, but the arrangement did not transfer the right to dispose of or alienate the property. The assessee continued to bear municipal levies and other obligations, showing that the legal title remained with it. A claim of adverse possession was not established, since permissive occupation did not mature into hostile title merely by lapse of time. The plea based on the Urban Land Ceiling proceedings also failed, because no notification under the relevant vesting provision had been published and the property had not vested in the Government. The vacant portion also did not fall within any statutory exception to the definition of urban land, and the use for employee welfare was not one of the specified exclusions.

Conclusion: The land belonged to the assessee-company and was chargeable to wealth-tax; the assessee's contentions were rejected.

Ratio Decidendi: For wealth-tax, property continues to be assessable where the assessee retains legal title and the case does not fall within a statutory exclusion from the definition of urban land.

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