TMI Blog1983 (10) TMI 2X X X X Extracts X X X X X X X X Extracts X X X X ..... Gujarat High Court disposing of a number of wealth-tax references and answering the following question against the Revenue in each reference : " Whether in computing the net wealth of the assessee, the amount deductible in respect of liability of tax for any year for which the assessment is completed after the valuation date is the liability as ascertainable on the valuation date or the actual amount of tax subsequently assessed ? " The facts are substantially similar for different appeals and, therefore, it will be sufficient to set forth the facts in one of them alone. In Civil Appeal No. 1524 of 1973, the facts are these. In the computation of his net wealth for the assessment year 1962-63, the corresponding valuation date being M ..... X X X X Extracts X X X X X X X X Extracts X X X X ..... th of the assessee must be calculated on the basis of the tax as finally determined on assessment though the assessment may have been made subsequent to the valuation date, and not on the basis of tax computed in accordance with the returns filed by the assessee. In these appeals, it is contended on behalf of the Revenue that the High Court has erred, and that on a true construction of s. 2(m) of the W.T. Act, defining the expression " net wealth " the tax liability disclosed by the assessee in his returns should be taken as representing the debt owed by, the assessee on the valuation date. Now, it is settled law that an income-tax liability becomes crystallized on the last day of the previous year corresponding to the particular assessme ..... X X X X Extracts X X X X X X X X Extracts X X X X ..... ation in appeal before the AAC and thereafter the case may be carried in second appeal to the Appellate Tribunal, in reference to the High Court and ultimately in appeal before this court. At every stage, the endeavour of the authority, tribunal or court is to adjudicate on questions which will lead in the final result to a true determination of the tax liability. There may be cases where the assessment finally made may be reopened in accordance with the procedure and subject to the conditions stated in the relevant statute. There may also be cases where a rectification of apparent errors is effected pursuant to jurisdiction granted by the relevant statute. Both these proceedings are similarly intended for the true quantification of the tax ..... X X X X Extracts X X X X X X X X Extracts X X X X
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