K.C. Agrawal, CJ.

1. AT the instance of the Revenue, the following two questions have been referred by the Income-tax Appellate Tribunal under Section 27(3) of the Wealth-tax Act, 1957 (hereinafter referred to as "the Act"), for the opinion of the High Court :

"1. Whether, on the facts and in the circumstances of the case, the Tribunal was justified in law in holding that liabilities towards (i) provision for income-tax except to the extent of proposed dividend (sic) (ii) provision for gratuity, and (iii) proposed dividend were to be deducted from the value of assets of the company for the purpose of determining the value of unquoted shares of Paharpur Cooling Towers Pvt. Ltd. on the basis of break-up value method in accordance with Rule 1D of the Wealth-tax Rules, 1957 ? 2. Whether, on the facts and in the circumstances of the case, the Tribunal was justified in law in upholding the order of the Commissioner of Wealth-tax (Appeals) to the effect that the tax deducted at source appearing on the assets side of the balance-sheet should be deducted from the total value of the assets in computing the value of unquoted shares of Paharpur Cooling Towers Pvt. Ltd. on break-up value