Plain meaning controls taxation: gifts outside the specified gift-tax period remain includible in net wealth.

The proviso to section 4(1)(a) of the Wealth-Tax Act was construed according to its plain language: the phrase "for any assessment year commencing after 31 March 1964" qualified the gift-tax condition attached to the transferred asset, not the wealth-tax exemption itself. Gifts falling outside the specified gift-tax-linked period were therefore not excluded from the donor's net wealth. The Court rejected an alternative reading advanced for assessees and refused to adopt a strained construction merely to avoid possible constitutional difficulty, reaffirming that clear statutory language must be given effect as written.

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Issues: Whether the proviso to section 4(1)(a) of the Wealth-Tax Act, 1957 exempted only transfers by way of gift that were chargeable to gift-tax or exempt under section 5 of the Gift-Tax Act, 1958 for assessment years commencing after 31 March 1964, or whether gifts made before that date also qualified for exclusion from the donor's net wealth.

Analysis: The proviso was read according to its plain language. The words "for any assessment year commencing after the 31st day of March, 1964" were held to qualify the gift-tax condition attached to the transferred asset, not the commencement of the wealth-tax exemption. The later insertion of the words limiting the period up to 1 April 1972 confirmed that the exemption operated within a defined gift-tax-linked period. The alternative construction urged on behalf of the assessees was rejected as inconsistent with the text and structure of the proviso. The Court also declined to adopt a strained construction merely to avoid a possible constitutional challenge, holding that constitutional avoidance cannot override clear statutory language.

Conclusion: The proviso applied only to gifts falling within the specified gift-tax period, and gifts made earlier were not excluded from the donor's net wealth. The question referred was answered in the negative and against the assessees.

Final Conclusion: The revenue's appeal succeeded and the assessees' appeals failed, leaving the disputed transferred assets includible in the assessees' net wealth for the relevant assessment years.

Ratio Decidendi: Where the language of a taxing provision is clear, it must be given effect according to its plain meaning, and a construction to avoid possible unconstitutionality cannot be adopted to rewrite the statutory text.

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