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TMI Blog1987 (8) TMI 21X X X X Extracts X X X X X X X X Extracts X X X X ..... question of law in respect of the same assessee pertaining to the assessment years 1966-67 and 1968-69 to 1973-74. The common question of law as stated in the reference relating to the assessment year 1966-67 is as under: "Whether, on the facts and in the circumstances of the case, the Tribunal was justified in law in allowing deduction of income-tax liability pertaining to earlier years and qua ..... X X X X Extracts X X X X X X X X Extracts X X X X ..... earlier undisclosed amount of Rs. 3,04,000 was Rs. 76,000, being his 1/4th share in the income. The Wealth-tax Officer included the gross amount of Rs. 76,000 in the wealth of the assessee rejecting the assessee's contention that the income-tax payable thereon had to be deducted according to section 2(m) of the Wealth-tax Act, 1957. The Appellate Assistant Commissioner, however, upheld the assess ..... X X X X Extracts X X X X X X X X Extracts X X X X ..... , it was a " debt owed" within the meaning of section 2(m) of the Wealth-tax Act, 1957, on account of which the amount of tax due on this amount of Rs. 76,000 had to be deducted from the estimated value of the asset on the valuation date. It was pointed out that the ultimate quantification of the tax liability as a result of the settlement reached in 1975 did not have the effect of postponing the ..... X X X X Extracts X X X X X X X X Extracts X X X X ..... eme Court taking the same view. Following these decisions, the references have to be answered against the Revenue and in favour of the assessee. Consequently, all these references for the assessment years 1966-67 and 1968-69 to 1973-74 are answered in favour of the assessee and against the Revenue by holding that the Tribunal was justified in taking the view that the tax liability had to be dedu ..... X X X X Extracts X X X X X X X X Extracts X X X X
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