Madras High Court· 22 September 2026

Does the Finance Act 2013 amendment to Explanation 1 of Section 2(ea) of the Wealth Tax Act, 1957 apply with retrospective effect from 01.04.1993?

A.MOHAMED IBRAHIM v. Commissioner of Wealth Tax-I

TCA.292/2012 · 2026:MHC:3954 · TCA No. 293 of 2012
Coram: Justice Anita Sumanth · Justice S.Raveekumar

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Answer

The Finance Act 2013 amendment to Explanation 1 of Section 2(ea) applies with retrospective effect from 01.04.1993.

Yes. The Finance Act 2013 amendment to Explanation 1 of Section 2(ea) applies with retrospective effect from 01.04.1993. It therefore governed appeals for assessment year 2008-09, and the Department's counsel accepted that the issue stood covered by it.

Headnote

Wealth Tax Act, 1957 — s.2(ea) — Explanation 1, sub-clause (b) — Finance Act, 2013 — Agricultural land — Retrospective effect — Wealth Tax Act, 1957 — s.2(ea) — Agricultural land — Retrospective amendment — Held: By the Finance Act 2013 amendment to Explanation 1 of Section 2(ea), given retrospective effect from 01.04.1993, exemption extends to land used for agricultural purposes and so classified in the revenue records. Appeals allowed. (¶5)

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In the Court's own words

Paragraph 2Mr.Swarnavel, learned counsel for the assessees submits that the issue involved in these appeals stands covered by the amendment to Section 2(ea) of the Wealth Tax Act, 1957 (in short ‘Act’) vide Finance Act, 2013, with retrospective effect from 01.04.1993, and Mr.Mahalingam, learned Senior Standing Counsel appearing for the Department fairly accedes to the submission made.

Paragraph 5While so, the definition of ‘asset’ under Section 2(ea) was amended by insertion of sub-clause (b) to Explanation 1 thereof vide Finance Act 2013, by virtue of which, exemption from wealth tax was extended to land classified in the revenue records as agricultural land, and utilised for agricultural purposes. The amendment was given retrospective effect from 01.04.1993. In this case, the fact that the assessees have been carrying on agricultural activity on the subject lands is undisputed. The present appeals relate to AY 2008-09 and are allowed with the questions of law answered in favour of the assessee.

Acts & Sections

s.2(ea) Wealth Tax Act, 1957

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Also decided in this judgment

Does exemption under Section 2(ea) of the Wealth Tax Act, 1957 apply to land used for agricultural purposes and so classified in the revenue records?

Plain-language answer prepared by the LexStreak Editorial Desk — verify against the judgment. Source: Madras High Court. Corrections