AJIT K. SENGUPTA, J. ( 1 ) IN this reference under Section 27 (1) of the Wealth-tax Act, 1957, for the assessment years 1977-78, 1978-79 and 1979-80, the following question of law has been referred to this court :"whether, on the facts and in the circumstances of the case, the Tribunal was correct in holding that jewellery owned by the assessee is not covered by the exemption provided in Section 5 (1) (xiii) of the Wealth-tax Act, 1957, for works of art ?" ( 2 ) SHORTLY stated, the facts are that the assessee who owned certain jewellery claimed that jewellery was exempted under Section 5 (1) (xii) of the Act, on the ground that it consisted of works of art. The Wealth-tax Officer negatived the claim of the assessee and, on appeal, the action of the Wealth-tax Officer was confirmed by the Appellate Assistant Commissioner. On further appeal, at the instance of the assessee, the Tribunal upheld the order of the Appellate Assistant Commissioner. ( 3 ) AT the hearing Mr. Sukumar Bhattacharya, learned advocate appearing for the assessee, while conceding that the jewellery belonging to the assessee consisted of ornaments made of gold, contended that these items of assets being works of art were eligible for exemption under Section 5 (1) (xii) of the Act. It is his contention that the jewellery in question having been manufactured by employment of professional skill and fine workmanship had to be regarded as work of art. It was contended that Section 5 is not a charging section but a section providing for exemption in respect of certain assets while computing the net wealth of the assessee. ( 4 ) IT was submitted that, had the intention of the Legislature been to exclude jewellery from the articles of exemption mentioned in Clause (xii) of Section 5 (1) of the Wealth-tax Act, it would have been specifically mentioned in this clause too, as has been mentioned in Clauses (viii) and (xiii) to Section 5 (1 ). It was, therefore, submitted that, in view of the clear provisions of Section 5 (1) (xii), jewellery consisting of ornaments made of gold and/or other precious metals was eligible for exemption while computing the net wealth of the assessee. It was, therefore, submitted that, in view of the clear provisions of Section 5 (1) (xii), jewellery consisting of ornaments made of gold and/or other precious metals was eligible for exemption while computing the net wealth of the assessee. ( 5 ) ON behalf of the Revenue, the learned advocate contended that the interpretation sought to be placed on behalf of the assessee on the expression "work of art" occurring in Clause (xii) of Section 5 (1) was not correct. It was submitted that in view of Explanation 1 to Section 5 (1) (viii), ornaments made of gold and/or other precious metals were not eligible for exemption even if they could be said to be "work of art". ( 6 ) WE have considered the rival contentions. We are, however, unable to persuade ourselves to accept the contention raised on behalf of the assessee. It cannot be disputed that one of the external aids to construction is the history of the legislation. Regard must be had not only to the words used in the statute but also to the history of the legislation. If we look at the history of the legislation regarding the exemption for jewellery, it will be evident that the Legislature has made its intention clear that ornaments made of gold and/or any precious metals will not qualify for exemption under Section 5 (1 ). There is no dispute about the fact that the jewellery belonging to the assessee consisted of ornaments made of gold and/or precious metals. For the assessment years 1957-58 to 1962-63, an assessee was entitled to exemption under the then Section 5 (1) (xv) in respect of jewellery belonging to him, subject to a maximum of Rs. 25,000 in value. It may be noted that the then Section 5 (1) (xv) was omitted by the Finance Act, 1963, with effect from April 1, 1963. ( 7 ) UNDER Section 5 (1) (xv), as it stood at the material time, every assessee was entitled, for the assessment years 1957-58 to 1962-63, to deduct a sum of Rs. 25,000 from out of the value of the jewellery belonging to him whether the same was intended for his personal use or not, but under Section 5 (1) (viii), the value of all the jewellery intended for the personal use of the assessee stood excluded in the computation of the net wealth of the assessee. 25,000 from out of the value of the jewellery belonging to him whether the same was intended for his personal use or not, but under Section 5 (1) (viii), the value of all the jewellery intended for the personal use of the assessee stood excluded in the computation of the net wealth of the assessee. ( 8 ) HOWEVER, for and from the assessment year 1963-64, exemption in respect of jewellery has been taken away statutorily as a result of amendment of Section 5 (1) (viii) by the Finance (No. 2) Act, 1971, with retrospective effect from April 1, 1963. ( 9 ) FOR the purposes of Section 5 (1) (viii) and 5 (1) (xiii), the expression "jewellery" has been defined in Explanation 1 to Section 5 (1) (viii) which has been inserted by the Finance (No. 2) Act, 1971, with effect from April 1, 1972. According to Explanation 1, the expression "jewellery" includes ornaments made of gold, silver, platinum or any other precious metals or any alloy containing one or more of such metals, whether or not containing any precious or semi-precious stone, and whether or not worked or sewn into any wearing apparel, precious or semi-precious stones, whether or not set in any furniture, utensil or other article or worked or sewn into any wearing apparel. The above definition of the expression "jewellery" is operative for and from the assessment year 1972-73. ( 10 ) IN the case of CWT v. Arundhati Balkrishna [1970] 77 ITR 505, the Supreme Court held that the expression "other articles intended for the personal or household use of the assessee", in Section 5 (1) (viii), included jewellery which was held by the assessee for her personal or household use. The court further held that the exemption of jewellery up to Rs. 25,000 in value under Section 5 (1) (xv), as it existed prior to April 1, 1963, operated in respect of jewellery other than that held for personal or household use of the assessee. The interpretation placed by the Supreme Court on the provisions in Clauses (viii) and (xv) of Section 5 (1) revealed that these clauses did not bring out correctly the intention underlying them, namely, that, up to the assessment year 1962-63, jewellery should be exempted from wealth-tax only up to a value of Rs. The interpretation placed by the Supreme Court on the provisions in Clauses (viii) and (xv) of Section 5 (1) revealed that these clauses did not bring out correctly the intention underlying them, namely, that, up to the assessment year 1962-63, jewellery should be exempted from wealth-tax only up to a value of Rs. 25,000 and from the assessment year 1963-64 onwards, when the specific exemption in Section 5 (1) (xv) was omitted from the Act, jewellery should not at all qualify for exemption from wealth-tax. ( 11 ) WITH a view to bringing out this intention clearly and implementing the purpose underlying the withdrawal of exemption for jewellery altogether from wealth-tax from the assessment year 1963-64, Clause (viii) of Section 5 (1) of the Wealth-tax Act has been amended by Section 32 of the Finance (No. 2) Act, 1971, retrospectively from April 1, 1963, so as to exclude jewellery altogether from the purview of that clause. Further, the term "jewellery" has been given an extended meaning prospectively so as to include 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 ; and precious or semi-precious stones, whether or not set in any furniture, utensil or other article or worked or sewn into any wearing apparel. ( 12 ) THUS, the exclusion of jewellery from the purview of exemption was operative retrospectively from the assessment year 1963-64 and the extended meaning of the term "jewellery" became operative from April 1, 1972, for the assessment year 1972-73 and subsequent assessment years. The intention of the Legislature has been amply demonstrated in the amendments effected from time to time in not allowing any exemption or withdrawing exemption. It is precisely for this reason that the assessee sought to urge that jewellery would come within the purview of Section 5 (1) (xii ). Under Section 5 (1) (xii), the assessee is entitled to, for and from the assessment year 195,7-58, exemption, inter alia, in respect of "works of art" not intended for sale. Under Section 6 (1) (xiii), exemption has been given to drawings, paintings, photographs, prints and other heirlooms not falling within the purview of Section 5 (1) (xii) and not intended for sale but not including jewellery. Under Section 6 (1) (xiii), exemption has been given to drawings, paintings, photographs, prints and other heirlooms not falling within the purview of Section 5 (1) (xii) and not intended for sale but not including jewellery. It is the contention of Mr. Bhattacharya that, since by Section 5 (1) (xii) jewellery has not been specifically excluded, jewellery being a "work of art" should be entitled to exemption. We are, however, unable to accept this contention in view of the fact that the Legislature intended that jewellery as such would not be eligible for exemption. Where the Legislature intended that exemption would be allowed to jewellery, it has made provision therefor, as for example, in Section 5 (1) (xiv) exemption has been allowed in respect of heirloom jewellery of a Ruler. Such jewellery to be exempt must be in the possession of the former Ruler not being his personal property, and it must have been recognised by the Central Government as an heirloom ; the jewellery shall be permanently kept in India and shall not be removed outside India except for a purpose and period approved by the Board and all reasonable steps shall be taken for keeping the jewellery substantially in the original shape. In case any of the aforestated conditions is not being duly fulfilled, the Board has been empowered to withdraw such recognition retrospectively with effect from September 9, 1972, after recording reasons in writing. Where the recognition has been so withdrawn by the Board, wealth-tax shall become payable by the Ruler for all the assessment years after September 9, 1972, for which the jewellery was exempted on account of the recognition. This demonstrates that jewellery as such is not entitled to any exemption under the Wealth-tax Act ( 13 ) IN our view, jewellery having been considered separately, it will not come within the purview of "work of art". Even assuming that a piece of jewellery is a "work of art" and comes within the purview of Section 5 (1) (xii), it cannot be an ordinary piece of jewellery which is meant for personal use and which, by its very nature, is liable to be sold whenever such occasion arises. ( 14 ) FOR the foregoing reasons, we answer the question in this reference in the affirmative and in favour of the Revenue. There will be no order as to costs.