SRINIVASAN J.

In these four tax references a common question arises, that is, as to the proper interpretation of the expression "net wealth" as defined in the Wealth-tax Act In T. C. No. 210 of 1959 relating to the assessment year 1957-58, the assessee company made a return of its wealth on the basis of its balance-sheet made up to the 30th of June, 1956. It is admitted that that date is the valuation date for the purpose of wealth-tax assessment. The assessee deducted from the total wealth two sums as below

Rs

Proposed preference dividend ... 72, 000

Proposed ordinary dividend ... 2, 40, 000

It is common ground that the directors of the company made a recommendation to the general body that the dividends should be paid as mentioned above in their report dated November 26, 1956, and that the general body, at its meeting, held on December 29, 1956, approved the balance-sheet and the directors' report and sanctioned the payment of the dividends proposed. The Income-tax Officer refused to allow the deduction of these sums as deductions properly allowable in the computation of the net wealth ; and the appeal to the Appellate Assistant Commissioner also failed, that authority tak