JUDGMENT In this case we are concerned with wealth-tax on property situated at Plot No. 39, Site IV, Sahibabad. concerned assessment year is 1984-85. facts are that appellant before us is company which manufactures bed sheets. It contends that it's own subsidiary company, namely, M/s. Dior International Pvt. Ltd., is company under same management and is doing processing work, namely, dyeing, for assessee-company in part of factory building situate at aforesaid property. It is not disputed that M/s. Dior International Pvt. Ltd. installed its own machinery for said job work of dyeing and that assessee charged sum of Rs. 20,000 per month as licence fee from M/s. Dior International Pvt. Ltd. said sum of Rs. 20,000 per month charged as licence fee has been claimed by assessee to be business income. Further, it is also clear that job work undertaken by M/s. Dior International Pvt. Ltd., though done wholly for assessee, was none less charged to assessee's account and paid for by assessee. question that arises on facts in this case is whether under section 40(3)(vi) of Finance Act, 1983, "the building" is used by assessee as factory for purpose of its business. Section 40(3) is set out herein below: "The assets referred to in sub-section (2) shall be following, namely:- (i) gold, silver, platinum or any other precious metal or any alloy containing one or more of such precious metals (not being any such precious metal or alloy held for use as raw material in industrial production; (ii) precious or semi-precious stones whether or not set in any furniture, utensil or other article or worked or sewn into any wearing apparel; (iii) ornaments made of gold, silver, platinum or any other precious metal or any alloy containing one or more of such precious metals, whether or not containing any precious or semi-precious stone, and whether or not worked or sewn into any wearing apparel; (iv) utensils made of gold, silver, platinum or any other precious metal or any alloy containing one or more of such precious metals; (v) land other than agricultural land: (Provided that nothing in this clause shall apply to any unused land held by assessee for industrial purposes for period of two years from date of its acquisition by him;) (vi) building or land appurtenant thereto, other than building or part thereof used by assessee as factory, godown, warehouse, hotel or office for purposes of its business or as residential accommodation for its employees or as hospital, creche, school, canteen, library, recreational center, shelter, rest- room or lunch room mainly for welfare of its employees and land appurtenant to such building or part: (via) any building used as residential accommodation in nature of guest house and land appurtenant thereto; (vib) any building and land appurtenant to such building used as residential accommodation by any director, manager, secretary or any other employee of assessee, such employee holding not less than one per cent of equity share of assessee or by any relative of any person who holds not less than one per cent. of equity share of assessee." By order dated March 9, 1989, assessing authority held that on these facts they had no hesitation in holding that part of building given to M/s. Dior International Pvt. Ltd. on licence is not being used for assessee's own business and, therefore, assessee is not entitled to exemption in respect of said part of Sahibabad building property. On appeal to Commissioner of Income-tax (Appeals), Commissioner by judgment dated January 28, 1993, agreed with assessing authority and dismissed appeal. Commissioner opined that Assessing Officer should refer matter to Valuation Officer under section 16A(1)(b)(ii) for valuation of portion given on rent by appellant company to its licensee. In further appeal to Income-tax Appellate Tribunal, Income-tax Appellate Tribunal agreed with view of authorities below and dismissed appeal. It held as follows: "The expression'used by assessee as factory... for purpose of its business' used by Legislature in aforesaid clause clearly shows that building or part of such building which is to be excluded from net wealth must be used by assessee as factory for purpose of its own business... In present case, there is no dispute that portion of building was let out to its sister concern, M/s. Dior International P. Ltd., which is subsidiary company of assessee at rent of Rs. 20,000 p. m. Further, Assessing Officer has given finding that it was M/s. Dior International P. Ltd. which had installed machinery for purpose of its own business of manufacturing of readymade garments. This factual aspect is not controverted by assessee. hon'ble Bombay High Court in case of Phaltan Sugar Works Ltd. v. CWT [1994] 208 ITR 989 (Bom) has held that business of subsidiary company cannot be considered as business of parent company. In eye of law, both are independent entities. No doubt, M/s. Dior International P. Ltd. was manufacturing garments for assessee but it was charging price for same from assessee and assessee was charging rent for use of premises. Therefore, only relationship between parties was that of lessor and lessee and nothing else. Therefore, contention of assessee that M/s. Dior International was manufacturing garments for assessee, in our opinion, would not advance case of assessee and is, therefore, rejected. In view of above discussion, it is held that portion of building belonging to assessee was in fact used by M/s. Dior International for its own use of manufacturing activity and, consequently, it cannot be said that such portion of building was used by assessee for purpose of its own business of manufacturing as factory. Therefore, such portion of building was rightly included by lower authorities in net wealth of assessee- company. However, in clause (vi) of sub-section (3) of section 40 of Finance Act, 1983, Legislature has specifically provided that building must be used as factory by assessee himself. In view of this distinguishing factor, said judgment of hon'ble Supreme Court cannot be applied to present case. observations of hon'ble Supreme Court at page 314 of 231 ITR, on which reliance was placed by learned counsel for assessee, do not advance case of assessee inasmuch as those observations were made in context of language of section 32A. In present case, it is not case of assessee to lease out building. Further, mere user for purpose of business is not sufficient for purpose of claiming exemption under section 40 of Finance Act, 1983. As observed earlier, use must be by assessee himself as factory, that is, for purpose of business of manufacturing carried on by him. Since in present case admittedly premises were actually used by lessee and not by assessee, we are unable to accept contention of learned counsel for assessee." Mr. Sabharwal, learned senior counsel for appellant, has argued two points before us and has relied on number of judgments. According to learned counsel, object sought to be achieved by section 40 is paramount. He pointed out that wealth-tax was abolished so far as companies were concerned by Finance Act, 1960, and revived qua closely held companies only by section 40 of Finance Act, 1983, with effect from assessment year 1984- 85. object, according to learned counsel, was to tax non-productive assets and it is clear that on facts according to learned counsel present is case of productive asset as part of building was used "for purpose of assessee's business". Further, learned counsel stated that not only must object of section be viewed to arrive at true interpretation of section 40 but equally this being commercial transaction it must be looked at commercially and if looked at commercially it is clear that assessee really undertakes various processes under same roof by itself and by sister concern, both being under same management and, therefore, asset, namely, building, is used by assessee commercially speaking for purpose of assessee's own business. Mr. Guru Krishan Kumar, learned senior counsel on behalf of respondent, drew our attention to assessment order, Commissioner of Income-tax (Appeals) order and Tribunal order referred to hereinabove and argued that it was very difficult to pierce corporate veil in case like present and stated that two companies are separate entities in law even though they are under same management. He pointed out that in fact Rs. 20,000 per month charged as licence fee and treated as income from business so far as assessee was concerned showed that transaction in present case was at arm's length and that both companies, therefore, observed corporate form and did not behave as part of single group. He further added that fact that job work done by M/s. Dior International Pvt. Ltd. was charged for by assessee-company further buttresses this submission. judgment under appeal passed by High Court of Delhi is short one page judgment referring to Tribunal and agreeing with its reasoning. We are of view that judgments of authorities below, Tribunal and High Court are correct for reason that it is well-settled that in taxing statute one goes by plain language used. It is only in cases of ambiguity that one can construe language in accord with object sought to be achieved. Going by plain language it is clear that learned senior counsel appearing on behalf of appellant is only partially correct in that user of building is established on facts of case and, therefore, asset of company is being used productively and not otherwise. However, super-added to this condition is another condition, namely, that such user must be "by assessee". Not only must it be by assessee but it must also be "for purpose of its business". It is clear on facts here that appellant before us and M/s. Dior International Pvt. Ltd. are doing their own business and are separately assessed as such. Mr. Guru Krishan Kumar, learned senior counsel is right in contending that on facts charging of Rs. 20,000 per month as licence fee by appellant-assessee from M/s. Dior International Pvt. Ltd. changes complexion of case. It is clear that once this is done, two companies, though under same management, are treating each other as separate entities. Also, he correctly pointed out that for job work done by M/s Dior International Pvt. Ltd., M/s Dior International Pvt. Ltd. was charging assessee-company and this again established that two companies preserved their individual corporate personalities so far as present transaction is concerned. Shri Sabharwal cited judgment of this court reported in CIT v. Malayalam Plantations Ltd. [1964] 53 ITR 140 (SC), and brought to our notice passage at page 150 which reads as follows: "The aforesaid discussion leads to following result: expression'for purpose of business' is wider in scope than expression'for purpose of earning profits'. Its range is wide: it may take in not only day to day running of business but also rationalisation of its administration and modernisation of its machinery; it may include measures for preservation of business and for protection of its assets and property from expropriation, coercive process or assertion of hostile title; it may also comprehend payment of statutory dues and taxes imposed as pre-condition to commence or for carrying on of business; it may comprehend many other acts incidental to carrying on of business. However wide meaning of expression may be, its limits are implicit in it. purpose shall be for purpose of business, that is to say, expenditure incurred shall be for carrying on of business and assessee shall incur it in his capacity as person carrying on business." It is true that expression "for purpose of business" may be wide but as judgment says its limits are also clear. expenditure incurred, therefore, will have to be for carrying on of business and assessee shall incur it in its capacity as person carrying on business. On facts here it is clear that assessee, namely, M/s. Kapri International (P.) Ltd., appellant before us, has not incurred anything in its capacity as person carrying on business. On other hand, it is clear on facts that it is M/s Dior International Pvt. Ltd. in its separate individual capacity that is carrying on its own business. This case is, therefore, clearly distinguishable on facts. He also cited before us judgment reported in CEPT v. Shri Lakshmi Silk Mills Ltd. [1951] 20 ITR 451 (SC) where controversy was whether, when dyeing plant of company remains idle because of difficulty in obtaining raw material, and it was temporarily let out, amount received in hands of such company could be treated as business income. passage cited at pages 455- 456 of report again makes it clear that this judgment does not in any manner further argument of assessee in present case. It goes as far as saying that on facts here Rs. 20,000 licence fee per month ought to be treated as business income. This may well be correct but as we have pointed out hereinabove, this fact does not further assessee's case in that very factum of charging Rs. 20,000 per month makes it clear that assessee treated itself as corporate personality separate from its subsidiary. Learned counsel for appellant then cited judgment of this court reported in S. A. Builders Ltd. v. CIT (Appeals) [2007] 288 ITR 1 (SC) in which question arose in context of section 36 of Income-tax Act as to whether interest-free loan given to sister concern can be said to be "for purpose of business". This does not take assessee very much further. interest-free loan may well on facts be treated to be "for purposes of business" so far as section 36 of Income-tax Act is concerned. However, on facts here we are concerned with very different provision in which user of premises has to be by assessee itself and not by its sister concern. This case is also distinguishable on facts. Learned counsel also cited Full Bench judgment of Madras High Court in case of CWT v. Fagun Co. P. Ltd. [2006] 286 ITR 297 (Mad) [FB] and drew our attention to passage at pages 313-314 of report. In that case, assets were let out by leasing company doing leasing business. On facts therefore, it was held that such leased assets would be treated as being for purpose of business in that case. This judgment also does not carry appellant's case any further. We, therefore, dismiss appeal, agreeing with reasoning of Appellate Tribunal, which has found favour with High Court. *** Kapri International (P.) Ltd. v. Commissioner of Wealth-tax