Tax on concealed income deemed a new liability, limiting deductibility for wealth valuation and prompting departmental review. The Gujarat High Court held that tax paid under section 68 of the Finance Act, 1965 is a new liability in respect of a particular item of income and thus cannot be deducted as a debt owed by the assessee on the last day of the relevant accounting year for computing net wealth. In consequence, the Board's Instruction No. 659, which allowed deduction of such tax where spread-over of income was accepted, is under review; officers are instructed to keep adverse cases alive by filing reference applications or leave petitions for valuation dates prior to 1-3-1965.
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Tax on concealed income deemed a new liability, limiting deductibility for wealth valuation and prompting departmental review.
The Gujarat High Court held that tax paid under section 68 of the Finance Act, 1965 is a new liability in respect of a particular item of income and thus cannot be deducted as a debt owed by the assessee on the last day of the relevant accounting year for computing net wealth. In consequence, the Board's Instruction No. 659, which allowed deduction of such tax where spread-over of income was accepted, is under review; officers are instructed to keep adverse cases alive by filing reference applications or leave petitions for valuation dates prior to 1-3-1965.
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