Revocable leasehold salt lands excluded from wealth-tax assets where the interest was not available beyond the permissible period.

Revocable leasehold salt lands were treated as outside the lessee's wealth-tax base because the lease could be revoked at the end of each season and was therefore not available to the assessee beyond the permissible period. The construction accepted for section 2(e)(v) of the Wealth-tax Act was that the expression covered interests available for a period not exceeding six years. On that footing, the leasehold interest fell within the statutory exception and was not an assessable asset for wealth-tax purposes.

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Issues: Whether revocable leasehold salt lands could be regarded as assets of the lessee for computation of wealth-tax.

Analysis: The lease contained a term enabling revocation at the end of each season, making the arrangement revocable in character. On that basis, the leasehold interest was treated as falling within the statutory exception under clause (v) of section 2(e) of the Wealth-tax Act, as the interest was not available to the assessee beyond the permissible period. The stated construction of the expression in section 2(e)(v) that it referred to availability for a period not exceeding six years was accepted, and the leasehold was held not to constitute an assessable asset for wealth-tax purposes.

Conclusion: Revocable transactions like leasehold salt lands could not be regarded as assets of the lessee for computation of wealth-tax.

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