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1983 Supreme(SC) 339

E.S.VENKATARAMIAH, R.S.PATHAK
Commissioner Of Wealth Tax, Gujarat – Appellant
Versus
Vadilal Lallubhai – Respondent


Advocates:
A.K.VERMA, A.SUBASHINI, B.B.Ahuja, F.S.NARIMAN, K.J.JOHN, S.C.Manchanda

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 date





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