Contextual interpretation of "individual" under wealth-tax law includes a female assessee and covers transfers to a minor son.

Section 4(1)(a)(ii) of the Wealth-tax Act was read contextually to include a female within the term "an individual", because the provision is anti-avoidance in character and the General Clauses Act makes masculine words include females unless the statute shows a contrary intention. The opening words "as belonging to him" did not require a male-only construction, and the language and object of section 4 were held materially different from the corresponding Income-tax Act provision. On that construction, assets transferred by a female assessee to her minor son were liable to be included in her net wealth.

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Issues: Whether, for purposes of section 4(1)(a)(ii) of the Wealth-tax Act, the expression "an individual" includes a female so that assets transferred by a female assessee to her minor son are liable to be included in her net wealth.

Analysis: Section 3 charges wealth-tax on every individual and section 4 is an anti-avoidance provision requiring inclusion of certain transferred assets in the net wealth of an individual. The expression "an individual" in section 4(1)(a)(ii) must be read in its context and not confined to a male merely because the opening words use the words "as belonging to him". Section 13 of the General Clauses Act applies, so words importing the masculine gender include females unless the context otherwise requires. The structure and object of section 4 do not compel a male-only construction, and the language of section 4 differs materially from the corresponding provision in the Income-tax Act, 1922.

Conclusion: The expression "an individual" in section 4(1)(a)(ii) includes a female assessee. The value of the shares transferred by the assessee to her minor son was liable to be included in her wealth-tax assessments.

Ratio Decidendi: In construing an anti-avoidance charging provision, the term "individual" is to be given a context-sensitive and inclusive meaning, and, by virtue of the General Clauses Act, the masculine form includes a female unless the statute indicates a contrary intention.

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