Agricultural land character for wealth-tax purposes remains unchanged by temporary government requisition or municipal inclusion.

For wealth-tax purposes, the character of land is determined by its inherent nature and ordinary user at the relevant valuation date, and temporary requisition by the Government does not by itself convert agricultural land into non-agricultural land. The land remained assessed to land revenue, was irrigated by canal water, and grass was grown on it as a crop; its agricultural surroundings and the duty to restore requisitioned property supported retention of its basic character. Inclusion in a town planning scheme and location within municipal limits were not enough to alter that character. The land was therefore agricultural land within section 2(e)(i) of the Wealth-tax Act, 1957, and not includible in taxable wealth.

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Issues: Whether land requisitioned by the Government, used as a police parade ground, included in a town planning scheme, and situated within municipal limits retained its character as agricultural land for the purposes of section 2(e)(i) of the Wealth-tax Act, 1957.

Analysis: The decisive enquiry was the nature and character of the land at the relevant valuation dates, not merely its temporary use after requisition. The land remained assessed to land revenue, was irrigated by canal water, and grass was grown on it as a crop. Its surroundings were still agricultural, and the requisition did not alter its inherent character. Inclusion in a town improvement scheme or location within municipal limits did not by itself convert agricultural land into non-agricultural land. The statutory obligation to restore requisitioned property in as good a condition as when taken further supported the conclusion that requisition did not change the basic nature of the land.

Conclusion: The land was agricultural land within section 2(e)(i) of the Wealth-tax Act, 1957, and was not includible in the assessee's taxable wealth. The answer was in favour of the assessee.

Ratio Decidendi: For wealth-tax purposes, the character of land is determined by its inherent nature and ordinary user at the relevant time, and temporary requisition or use by the Government does not change agricultural land into non-agricultural land unless the land's essential agricultural character is lost.

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