Judgment

VENKATARAMIAH, J.:- On the basis of a certificate granted under Section 29 (1) of the Wealth-tax Act, 1957 (hereinafter referred to as the Act), the appellant has filed these appeals against the judgment and order dated December 21, 1972 of the High Court of Gujarat in Wealth-tax Reference No. 2 of 1969. The questions refered to the High Court under Section 27 of the Act by the Income-tax Appellate Tribunal, Ahmedabad Bench read thus :

"(1). Whether on the facts and in the circumstances of the case the liability in respect of income-tax payable on the concealed income disclosed by the assessee pursuant to Section 68 of the Finance Act. 1965 is, deductible under Section 2 (m) of the Wealth-tax Act, 1957, in computing net wealth of the assessee for the assessment years 1959-60, 1960-61, 1961-62, 1962-63, 1963-64 and 1964-65.

(2) Whether the Tribunal was right in holding that the liability to pay tax on the amount disclosed under Section 68 of the Finance Act, 1965, arose not under that Finance Act but under S. 3 of the Indian Income-tax Act, 1922."

2. Having regard to the assessment years in question, the second question should be read as including within its scope also the ques