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Section 2 (e) of the Wealth-tax Act, 1957 - Assets - Assessment year 1959-60 - Whether revocable transactions like leasehold salt lands could be as regarded as assets of lessee for computation of wealth-tax - Held, no FACTS The assessee had taken on lease certain lands for preparation of salt. For the assessment year 1959-60, the assessee's, claim that these lands should be excluded from the assets for determining the net wealth was rejected. On reference: HELD In view of the decision of the Supreme Court in CWT v. Srimathi Martinammal Machado [1964] 54 ITR 687 it was held that revocable transitions like leasehold salt lands could not be regarded as assets of lessee for computation of wealth-tax. Note: The case has been decided in favour of the assessee. CASES REFERRED TO CWT v. Smt. Martinammal Machado [1964] 54 ITR 687 (Mad.) and CWT v. Smt. Muthukrishnammal [1969] 72 ITR 801 (SC). JUDGMENT G.K. Misra, CJ.-The facts leading to this reference may be stated in brief. The assessment year is 1959-60. The assessee had taken lease of about 900 acres of land for preparation of salt. These lands were valued at Rs. 1,54,000 for the purpose of wealth-tax on June 30, 1958. The assessee contended that these lands should be excluded from the assets for determining the net wealth under the Wealth-tax Act. This contention was rejected. A reference was also rejected and the assessee ultimately came to the High Court. On September 5, 1966, this court called for a reference on the following question: "Whether, on the facts and circumstances of the case, revocable transactions like leasehold salt lands could be regarded as assets of the lessee for computation of wealth-tax ?" An identical case came up for consideration in Commissioner of Wealth-tax v. Srimathi Martinammal Machado [1964] 54 ITR 687 ,where their Lordships held that a leasehold of the type…

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