Judgment

PATHAK, J. :- These appeals are directed against the judgment of the Gujarat High Court disposing of a wealth tax reference and answering the following question of law against the Revenue :

"Whether, on the facts and in the circumstances of the case, the Tribunal was right in holding that the provisions of S. 2(m)(iii)(a) were not applicable in respect of liabilities arising under the wealth tax assessments of the assessee for the assessment years 1960-61 and 1961-62?"

2. For the purpose of determining the assessees net wealth in assessment proceedings under the Wealth-tax Act in respect of the assessment years 1961-62 and 1962-63, the corresponding valuation dates being March 31, 1961 and March 31, 1962, the assessee claimed a deduction of certain sums representing the estimated liabilities on account of income tax and wealth tax. The claim was rejected by the Wealth-tax Officer in both assessments, On appeal by the assessee, the Appellate Assistant Commissioner of Wealth Tax allowed a part of the claim. In the appeal pertaining to the assessment year 1961-62, he allowed a deduction of Rs. 22,679/- on account of wealth tax relating to the assessment year 1960-61, Rs. 36,692/