The Appellate Assistant Commissioner scrutinised the data placed before him and allowed part of the deductions claimed.
6 to 11, 13, 15, 17, 18, 22,24 and 25 of 1971, 34, 39, and 40 of 1970, 20 and 42 of 1971, 22, 35, 41,42,43 38 of 1970.
Similar references were made in other cases, and all of them were disposed of by a companymon judgment of the High Court dated December 13, 1972.
From the Judgment and Order dated 13.12.1972 of the Gujarat High Court in Wealth Tax References Nos.
CIVIL APPELLATE JURISDICTION Civil Appeal Nos.
In Civil Appeal No.
The Appellate Tribunal rejected the companytention and dismissed the appeal.
The facts are substantially similar for different appeals and therefore it will be sufficient to set forth the facts in one of them alone.
C. Manchanda, B.B. Ahuja and Miss A. Subhashini for the Appellant.
1524 of 1973 the facts are these.
The Judgment of the Court was delivered by PATHAK, J These appeals are directed against the judgment of the Gujarat High Court disposing of a number of wealth tax references and answering the following question against the Revenue in each reference Whether in companyputing the net wealth of the assessee, the amount deductible in respect of liability of tax for any year for which the assessment is the companypleted after the valuation date is the liability as ascertainable on the valuation date or the actual amount of tax subsequently assessed ?
S. Nariman, Mrs. A.K. Verma and K.J. John for the Respondents.
The Wealth Tax Officer rejected the claim on the ground that as those liabilities were claimed on the basis of an estimate they companyld number be regarded as debts owed on the valuation dates.
1524 47 of 1973.
The Revenue number appealed to the Appellate Tribunal, and companytended that the deductions on account of income tax, wealth tax and gift tax liabilities for the assessment year 1962 63 should have been allowed on the basis of the respective returns filed by the assessee and number on the basis of the final assessment as the assessment orders were made after the valuation date.
In the companyputation of his net wealth for the assessment year 1962 63, the companyresponding valuation date being March 31, 1962, the assessee claimed a deduction in respect of debts which included amounts representing estimated liabilities on account of income tax and wealth tax for the assessment year 1962 63.
In appeal before the Appellate Assistant Commissioner of Wealth Tax the assessee claimed the deduction of a larger sum on account of income tax, wealth tax and gift tax liabilities.
At the instance of the Revenue, the Appellate Tribunal referred the case to the Gujarat High Court for its opinion on the question of law set forth earlier.
