JUDGMENT

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 computing the net wealth of the assessee, the amount deductible in respect of liability of tax for any year for which the assessment is completed after the valuation date, is the liability as ascertainable on the valuation date or the actual amount of tax subsequently assessed?"

The facts are substantially similar for different appeals and therefore it will be sufficient to set forth the facts in one of them alone. In Civil Appeal No. 1524 of 1973 the facts are these.

2. In the computation of his net wealth for the assessment year 1962-63, the corresponding 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. The Wealth-tax Officer rejected the claim on the ground that as those liabilities were claimed on the basis of an estimate they could not be regarded as debts owed on the valuation dates. 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. The Appellate Assistant Commissioner scrutinised the data placed before him and allowed part of the deductions claimed. The Revenue now appealed to the Appellate Tribunal, and contended 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 not on the basis of the final assessment as the assessment orders were made after the valuation date. The Appellate Tribunal rejected the contention and dismissed the appeal. 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. Similar references were made in other cases, and all of them were disposed of by a common judgment of the High Court dated December 13, 1972. The High Court, relying on its earlier judgment in Commr. of Wealth-tax v. Kantilal Manilal (1973) 88 ITR 125 held that the deduction admissible, in computing the net wealth of the assessee must be calculated on the basis of the tax as finally determined on assessment though the assessment may have been made subsequent to the valuation date, and not on the basis of tax computed in accordance with the returns filed by the assessee.

3. In these appeals, it is contended on behalf of the Revenue that the High Court has erred, and that on a true construction of Section 2(m) of the Wealth-tax Act defining the expression "net wealth" the tax liability disclosed by the assessee in his returns should be taken as representing the debt owed by the assessee on the valuation date. Now, it is settled law that an income-tax liability becomes crystallized on the last day of the previous year corresponding to the particular assessment year, and a wealth-tax liability becomes crystallized on the valuation date corresponding to the particular assessment year. In each case the liabilities are perfected debts on the last day of, the previous year or the valuation date, as the case may be. See Kesoram Industries and Cotton Mills Ltd. v. Commissioner of Wealth-tax (Central), Calcutta (1966) 59 ITR 767 and H. H. Setu Parvati Bayi v. Commr. of Wealth-tax, Kerala (1968) 69 ITR 864. Likewise, we think a gift-tax liability becomes crystallized, and therefore a perfected debt, on the last day of the previous year relevant to the particular assessment year. See Commr. of Wealth-tax, Madras v. K. S. N. Bhatt, Civil Appeals Nos. 384 to 387 of 1978, Judgment delivered on October 21, 1983. The object and purpose of the assessment procedure prescribed by