Broad reading of power distribution under wealth-tax exemption covers LPG supply through cylinders as industrial undertaking activity.

Section 5(1)(xxxii) of the Wealth-tax Act was construed broadly to cover not only generation but also distribution of power, and the term "power" was treated as including energy sources such as gas. On that reading, supplying liquefied petroleum gas through cylinders amounted to distribution of power because the cylinders were only a mode of physical delivery. The firm was therefore regarded as an industrial undertaking engaged in distribution of power, and the partner was entitled to the exemption.

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Issues: Whether the assessee, as a partner in a firm engaged in supplying and distributing liquified petroleum gas through gas cylinders, was entitled to exemption under section 5(1)(xxxii) of the Wealth-tax Act on the footing that the firm was an industrial undertaking engaged in the distribution of power.

Analysis: The exemption covered not only the generation of electricity or other forms of power but also their distribution. The expression "power" was construed broadly to include energy or source of energy such as electricity, coal, kerosene, oil and gas. Since gas cylinders constituted a mode of physical delivery of gas, distribution through cylinders amounted to distribution of a form of power. The firm's activity, therefore, satisfied the statutory requirement of an industrial undertaking engaged in the distribution of power.

Conclusion: The assessee was entitled to the exemption under section 5(1)(xxxii) of the Wealth-tax Act.

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