JUDGMENT

PATHAK, J.:—This appeal is directed against the judgment of the Gujarat High Court disposing of a wealth-tax reference and answering against the Revenue the following two questions:

"Whether on the facts and in the circumstances of the case the assessee is entitled to the deduction of-

(i) income-tax liabilities for the assessment years 1962-63, 1963-64 and 1964-65; wealth-tax for the assessment year 1964-65 and gift-tax for the assessment years 1962-63 to 1964-65 as determined payable on the basis of the assessment orders passed after the valuation date, and

(ii) income-tax liability for the assessment years 1958-59 and 1960-61 and wealth-tax liability for the year 1961-62 created as a result of rectification orders passed after the relevant valuation date in determining the value of the net wealth?"

In assessment proceedings under the Wealth-tax Act for the assessment year 1964-65, the respondent assessee claimed a deduction of Rs. 2,42,535/- in the computation of her net wealth, on the ground that the amount represented the assessees tax liabilities for different years. The Wealth-tax Officer rejected the claim. An appeal by the assessee was allowed by the Appellate Assista