COMMISSIONER OF WEALTH-TAX, CALCUTTA vs O.M.M. KlNNISON (DEAD) THROUGH HER EXECUTORS & T:RUSTEES

The Supreme Court ruled that under Section 6(i) of the Wealth Tax Act, 1957, the widow of 'D' is liable to wealth tax on her interest in Indian assets held in trust, as her rights in the shares and managing agency income are considered tangible movable properties located in India. The Court upheld the Appellate Tribunal's decision that the assets were taxable despite her non-resident status, rejecting her claim for exemption under sub-clause (iv) of clause (e) of Section 2. The Court emphasized that the nature of the property and its location in India determined tax liability, affirming the assessments for the years 1957-58 to 1962-63.