JUDGMENT

Bharucha, J.-Civil Appeal No. 2717 of 1996 :

The appeal relates to the Assessment Year 1980-81. It is on a certificate of fitness to appeal granted by the High Court. The certification was only in respect of one question, which read thus :

"Whether on the facts and in the circumstances of the case, the liability to pay surtax is an admissible deduction in computing the total income?"

2. The answer to this question is covered against the assesee by the decision of this Court in the assessee s own cases, 219 ITR 581. The question is, accordingly, answered in the negative and in favour of the Revenue.

3. The civil appeal is dismissed.

4. No order as to costs.

Civil Appeal Nos. 4545-4547 of 1996 :

5. These are appeals from the judgment and order of the Division Bench of the Karnataka High Court in Income Tax References. The questions that the High Court was called upon to answer read thus :

"Question of law in ITRC 144 of 1993

(a) Whether on the facts and in the circumstances of the case, the liability to pay surtax is an admissible deduction in computing the total income?

(b) Whether on the facts and in the circumstances of the case, the expenditure