JUDGMENT

TULZ.APURKAR, J. :— The only question raised in these appeals is whether the two sums of Rs. 5,40,941/- (in the case of M/s. J. K. Cotton Ltd.) and Rs. 21,61,788/-(in the case of J. K. Jute Ltd.) being the balance of the demands payable as a result of the findings and orders of the Income-tax Investigation Commission in the settlements made under the Taxation on Income (Investigation Commission) Act (30 of 1947) are deductible as debts owed by them in determining the net-wealth of these companies?

2. The question arises in these circumstances; M/s. J. K. Cotton Manufacturers Ltd., the assessee, is a limited company engaged in the manufacture of cotton textiles. etc. and the assessment involved is the wealth-tax assessment for the year 1957-58 based on the valuation date 30-9-1956. It appears that as a result of proceedings taken and a settlement arrived at in 1952 under the Taxation on Income (Investigation Commission) Act 1947, a sum of Rs. 15,99,041/- was determined as payable by the assessee company on its secreted profits and a scheme for the payment of the said liability by instalments was laid down. Out of this, a sum of Rs. 10,50,000/- had been paid before the valuat