Judgment :- Jayasimha Babu, J. Two questions have been referred, to us at the instance of the revenue, "1. Whether, on the facts and in the circumstances of the case, the Tribunal is night in law in holding that the additional wealth-tax is not leviable in respect of agricultural lands lying within 8 kms. of the Municipal Limit ? 2. Whether, on the facts and in the circumstances of the case, the Tribunal has valid materials to hold that the properties standing in the name of Vijayakumar Cotton Press are to be considered as used for business purposes and, hence, are exempt from levy of additional wealth-tax ?" 2. The assessment years are 1975-76 and 1976-77. The assessment was under the Wealth-tax Act, 1957 ('the Act'). 3. The assessee owns agricultural lands within 8 kms. from Coimbatore Municipal limit. The assessee also has a cotton press with godown known as 'Vijayakumar Cotton Press' in a portion of the land. The assessee claimed exemption from the additional wealth-tax on the ground that the land and the cotton press were used for the purpose of the business of the assessee. That claim has been accepted by the Commissioner and the Tribunal, though it had been negatived initially by the WTO. 4. The fact that the assesses is running a business under the name 'Vijayakumar Cotton Press' and that he has a ginning factory and godown on a portion of the land is not in dispute. That is what has been noticed by the WTO. That the character of the land owned by the assessee is agricultural land and that the assessee was carrying on agricultural activity in the area not covered by the ginning factory and godown has also not been disputed; there is no finding that the assessee was not using the land for carrying on agricultural operation. 5. Paragraph B of Part I of Schedule I of the Act which provides for the levy of additional wealth-tax specifically excludes the land and building used for the purpose of business or profession of the assessee, even when such lands are agricultural lands and are situated within 8 kms. of the municipal limit. The finding recorded by the Tribunal on this question as to whether the land used is for the business purpose is a finding of fact. That agriculture can also constitute business cannot be doubted. of the municipal limit. The finding recorded by the Tribunal on this question as to whether the land used is for the business purpose is a finding of fact. That agriculture can also constitute business cannot be doubted. The Supreme Court in the case of State of Andhra Pradesh v. Abdul Bakshi & Bros. held that, "The expression 'business' though extensively used, is a word of indefinite import. In taxing statutes it is used in the sense of an occupation or profession which occupies the time, attention and labour of a person, normally with the object of making profit. To regard an activity as business, there must be a course of dealing, either actually continued or contemplated to be continued with a profit motive, and not for sport or pleasure. The carrying on of activity of agriculture which necessarily involves time, attention and labour, is to be regarded as business if it is done with a profit motive and not for sport or pleasure. It is not the case of the revenue that the assessee herein was carrying on agricultural activity for sport or pleasure. Before the Commissioner as also before the Tribunal, the partners to appeal have proceeded on the assumption that the agricultural activity was done with profit motive and the offly point on which argument appears to have been advanced was whether the agricultural activity can at all be regarded as business. 6. Having regard to the law enunciated by the Supreme Court on the scope of the term 'business' and the finding recorded, by the Tribunal that the assessee is carrying on business in agriculture and is carrying on business of ginning factory on the land where agricultural activity is not carried on, we answer the two questions referred to us in favour of the assessee and against the revenue.