This judgment would dispose of two cross civil appeals Nos. 1491 and 1693 of 1971 which have been filed by special leave by the assessee M/s Tea Estate India (P) Ltd. and the Commissioner of Income tax West Bengal respectively against the judgment of the Calcutta High Court answering the following question referred to it under section 66(1) of the Indian Income tax Act 1922 (hereinafter referred to as the Act) partly in favour of the assessee and partly in favour of the revenue: Whether on the facts and in the circumstances of the case the balances in the under noted accounts are includible in the accumulated profits within the meaning of section 2(6A)(c) and if so to what extent? 148 Dibru Darang Taikrong Tea Tea Co. Ltd. Co. Ltd. Rs. Rs. Land A/o 19,30,374, 10,11,216/ Profit & Loss Account 16,69,285/ 18,73,125/ General Reserves and liabilities for taxation 3,50,799/ 2,243/ Reserve created on writing up the value of the assets of the ten estates 15,69,828/ 58,772/ The matter relates to the assessment year 1956 57, the corresponding accounting year for which ended on June 30, 1955.