Thus, the principal question which arose was: What is the meaning of "agricultural land" as that term is used in the Act ? The High Court of Kerala, which had to deal with this reference decided the question on two grounds: firstly, that, according to the views expressed in Sarojni Devi vs Srikrishna;(1) and Megh Raj vs Allah Rakha;(2) and C.I.T. West Bengal, Calcutta, vs Raja Benoy Kumar Sahas Roy,(3) the words "agricultural land" should be "interpreted in their widest significance"; and, secondly, that although the burden rested upon an assesee to establish an exemption from liability to estate duty in respect of any part of his estate, yet, if he claimed immunity on the ground that the subject matter does not fall within the ambit of the taxing power of the legislature imposing (1) A.I.R. 1944 Mad. 401.