ISSUE:
Whether Parliament has the power under residuary provisions to impose a wealth tax on agricultural land when such power is not explicitly mentioned in any of the three Lists of the Seventh Schedule?
Whether the Wealth Tax Act falls under Entry 86, List I or Entry 97, List I of the Constitution?
RULE:
The residuary power of Parliament includes any matter not enumerated in State List (List II) or Concurrent List (List III), even if it's not specifically mentioned in Union List (List I).
When interpreting constitutional distribution of powers, the content of residuary power does not change whether it's conferred on Parliament or States.
The Constitution makers intended to make the center strong by giving Parliament comprehensive residuary powers, including the power to impose taxes not mentioned in other lists.