JUDGMENT G. P. Singh, C.J. 1. This is a reference under section 27(1) of the Wealth Tax Act, 1957. The question of law referred is as follows:- Whether on the facts and in the circumstances of the case, the Appellate Tribunal was right in allowing exemption in respect of the value of gold and silver ornaments included in the value of jewellery under section 5(i) (viii) of the Wealth Tax Act, 1957?" 2. The assessee in the present reference is Smt Sonal K. Amin. The assessment year is 1971-72 and the relevant valuation date is 30th October 1970. The Wealth Tax Officer by order dated 29th March 1972 included Rs. 50,000 in the net wealth of the assessee as value of ornaments and jewellery. The order was maintained by the Appellate Assistant Commissioner. The Tribunal accepted the assessee's appeal and held that the gold and silver ornaments as distinguished from jewellery were not includible in the not wealth being articles of personal use. The Tribunal remanded the case to the Wealth Tax Officer for examining the correctness of the claim of the assessee in respect of such ornaments and to exclude their value from the net wealth. On an application made by the Commissioner of Wealth Tax, the Tribunal has referred the question which we have set out above. 3. Section 5 of the Act provides for exemption in respect of certain assets. Clause (viii) of section 5 (1) as originally enacted, granted exemption in respect of "furniture, household utensils, wearing apparel, provisions and. other articles intended for personal or household use of the assessee." Clause (xv) of the same section as originally enacted, allowed exemption in respect of "jewellery belonging to the assessee, subject to a maximum of twenty-five thousand rupees in value." These clauses were construed by the Supreme Court in C.W.T.V. Arundhati Balkrishna (1970) 77 ITR 505. It was held by the Supreme Court that jewellery intended for personal use of the assessee came within the scope of section 5(1) (viii) being "articles intended for personal use" and that section 5(1) (xv) dealt with jewel1ery in general whether intended for personal use of the assessee or not. To counteract the effect of this decision, clause (viii) was amended by Finance Act No.2 of 1971. To counteract the effect of this decision, clause (viii) was amended by Finance Act No.2 of 1971. The first amendment material for our purposes introduced by this Act in clause (viii) was to add the words "but not including jewellery" with retrospective effect from 1st April 1963. Another amendment to be taken notice of was addition of Explanation I with effect from 1st April 1972. As a result of this Act, clause (viii) of section 5(1) has to be read as follows with effect from 1st April 1963:- "(VIII) Furniture, household utensils, wearing apparel, provisions and other articles intended for personal or household use of the assessee but not including jewellery." The Explanation referred to above which was also added by the same Act with effect from 1st April 1972 is as under: Explanation 1 - For the purpose of this clause and clause (viii) "jewellery" includes- (a) Ornament 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: (b) Precious or semi-precious stones, whether or not set in any furniture, utensil or other article or worked or sewn into any wearing apparel." 4. Explanation I set out above was not applicable for the assessment year with which we are concerned in this case. The question before us is whether the words "but not including jewellery" which were added in clause (viii) with retrespective effect from 1st April 1963, on a proper construction by themselves and without the aid of the Explanation, cover gold and silver ornaments not containing any precious or semi-precious stones. There appears to be a sharp divergence of opinion on this question. The Gujarat, Allahabad and Punjab and Haryana High Courts have taken the view that the work "jewellery" would cover gold and silver ornaments irrespective of whether they are studded with precious stones or not and that the Explanation was added as a matter of abundant caution (See C.W.T.V. Jayantilal Amratlal (1976) 102 ITR 105 (Guj), C.W.T.V Maharaja Vibhuti Narainsingh (1979) 117 ITR 246 (Alla.) and C.W.T.V. Rajeshwar Parshad 1975 TLR 194 (Punj. & Har.). & Har.). Contrary view has been taken on this point by Orissa and, Calcutta High Courts; (See C.W.T.V. Binapani Chakeraberty (1978) ITR 82 (Orissa) and C.W.T.V. Aditya Vikram Birla (1978) ITR 711 (Cal.). Having given our anxious consideration to the problem, we arc inclined to agree with the view taken by the Orissa and Calcutta High Courts which held the view that by itself jewellery does not cover gold and silver ornaments not containing precious or semi-precious stones. 5. As the Explanation was added only with effect from 1st April 1972 defining the word "jewellery", we cannot use it for the assessment year 1971-72. The meaning of clause (viii) and the word "jewellery" has to be found out without the aid of the Explanation. The Compact Edition of the Oxford English Dictionary (Vol. 1, P. 1508) gives the following meaning of "jewel" and "jewellery" : "jewel: An article of value used for adornment, chiefly of the person a costly ornament, especially-one made of gold, silver, or precious stone. Obs-in general sense; now restricted to a small ornament containing a precious stone or stones, worn for personal adornment." "jewellery: jewellers' work; gems or ornaments made or sold by jewe1lers; especially-precious stones in mountings; jewels collectively or as a form of adornment." In the Reader's Digest Great Encylopaddic Dictionary (Oxford Illustrated Dictionary, Vol. I P. 468) the following meaning is given of the word "jewel". "jewel, Ornament containing precious stone (s) worn for personal adornment precious stone; highly prized person or thing.-V.t. Adorn, furnish, with jewels; fit (watch) with jewels for the pivot-holds. Jeweller, jewellery, jewelry ns." 6. A peruse I of the dictionary meanings quoted above will go to show that in its generic sense the word "jewel" was capable of including costly ornaments made of gold and silver. But this meaning has become obsolete and the word is now restricted to mean ornaments containing precious stone or stones. Similarly, the word "jewellery" normally connotes precious stones in mountings and not all kinds of gold and silver ornaments. The ordinary meaning of the word "jewellery", in our opinion, therefore, does not embrace gold and silver ornaments which do not contain precious stones and it is in this sence that this word has to be understood in clause (viii) before 1st April 1972. The ordinary meaning of the word "jewellery", in our opinion, therefore, does not embrace gold and silver ornaments which do not contain precious stones and it is in this sence that this word has to be understood in clause (viii) before 1st April 1972. By the Explanation that was added with effect from 1st April 1972 a wider meaning is given to the word jewellery by including within it all ornaments whether or not containing any precious or semi-precious stones. But as this meaning became effective only from 1st April 1972, it cannot be used for restricting the exemption for any assessment year prior to that date. We do not accept the submission made by the learned counsel for the Commissioner of Wealth Tax that the Explanation was added as a matter of abundant caution. In our opinion, it was clearly added to give a wider meaning to the word "jewellery" with effect from 1st April 1972 and this wider meaning cannot be given for any prior assessent year. The very fact that the words "but not including jewellery" were retrospectively added with effect from 1st April 1963 and the Explanation was added only with effect from 1st April 1972 by the same Finance Act gives out the clear intention of Parliament that the wide meaning given in the Explanation IS not to be applied for any assessment year before 1st April 1972. 7. For the reasons given above, our answer to the question is that the Appellate Tribunal was right in allowing exemption in respect of the gold and silver ornaments under section 5(i) (viii) of the Wealth Tax Act, 1957. There will be no order as to costs of this reference.