Summarize the following court judgment. ivil Appeal Nos. 1524 47 of 1973. From the Judgment and Order dated 13.12.1972 of the Gujarat High Court in Wealth Tax References Nos. 6 to 11	 13	 15	 17	 18	 22	24 and 25 of 1971	 34	 39	 and 40 of 1970	 20 and 42 of 1971	 22	 35	 41	42	43 & 38 of 1970. S.C. Manchanda	 B.B. Ahuja and Miss A. Subhashini for the Appellant. F.S. Nariman	 Mrs. A.K. Verma and K.J. John for the Respondents. 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 March 31	 1962	 the assessee claimed a deduction in respect of debts which included amounts representing estimated liabilities on account of income tax and wealth tax for the assessment year 1962 63. The Wealth Tax Officer rejected the claim on the ground that as those liabilities were claimed on the basis of an estimate they could not be regarded as 487 debts owed on the valuation dates. In appeal before the Appellate Assistant Commissioner of Wealth Tax the assessee claimed the deduction of a larger sum on account of income tax	 wealth tax and gift tax liabilities. The Appellate Assistant Commissioner scrutinised the data placed before him and allowed part of the deductions claimed. The Revenue now appealed to the Appellate Tribunal	 and contended that the deductions on account of income tax	 wealth tax and gift tax liabilities for the assessment year 1962 63 should have been allowed on the basis of the respective returns filed by the assessee and not on the basis of the final assessment as the assessment orders were made after the valuation date. The Appellate Tribunal rejected the contention and dismissed the appeal. At the instance of the Revenue	 the Appellate Tribunal referred the case to the Gujarat High Court for its opinion on the question of law set forth earlier. Similar references were made in other cases	 and all of them were disposed of by a common judgment of the High Court dated December 13	 1972. The High Court	 relying on its earlier judgment in Commissioner of Wealth Tax vs Kantilal Manilal(1) held that the deduction admissible in computing the net wealth 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 section 2 (m) of the Wealth Tax 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 assessment year	 and a wealth tax liability becomes crystallized on the valuation date corresponding to the particular assessment year. In each case the liabilities are perfected debts on the last day of previous year or the valuation date	 as the case may be. See Kesoram Industries and Cotton Mills Ltd. vs Commissioner of Wealth Tax (Central)	 Calcutta(2) and H.H. Setu Parvati Bayi vs Commissioner of Wealth Tax	 Kerala.(3) Likewise	 we think a gift 488 tax liability becomes crystallized	 and therefore a perfected debt	 on the last day of the previous year relevant to the particular assessement year. See Commissioner of Wealth Tax	 Madras vs K.S.N. Bhatt (1) The object and purpose of the assessment procedure prescribed by the relevant tax statute	 be it the Income Tax Act	 the Wealth Tax Act or the Gift Tax Act	 is to quantify the precise amount of the tax liability. The process is initiated ordinarily by the assessee filing a tax return	 and thereupon the asssessment machinery swings into motion. The tax return is scrutinised by the assessing authority and in accordance with the procedure detailed in the relevant statute the assessing authority proceeds to determine the true figure	 in its opinion	 of the asseessee 's taxable income or taxable wealth or total value of the taxable gifts	 depending on whether it is a case of income tax	 wealth tax or gift tax. The assessment order made by the assessing authority specifies the assessed income	 wealth or value of the gifts	 and on that the corresponding tax liability is computed followed by a notice of demand. The assessment order may be subjected to consideration in appeal before the Appellate Assistant Commissioner 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 liability. When	 in the course of a wealth tax assessment	 the assessee makes a claim to deduction on account of income tax	 wealth tax and gift tax liabilities subsisting as debts owed by him on the valuation date	 it is the final quantification of the particular tax liability which must be taken into account. Where the wealth tax assessment so made is carried in appeal	 we have no doubt that the appellate authority will take into account the ultimate quantification of the tax liability	 even though such ultimate quantification has been reached after the relevant valuation date and during the pendency of the wealth tax appeal. 489 Upon the aforesaid considerations	 we are of opinion that the High Court has acted rightly in holding that in computing the net wealth of the assessee the deduction admissible must be calculated on the basis of the tax as finally quantified on assessment even though the assessment may have been made subsequent to the valuation date. Once an assessement order is passed	 the data disclosed by the assessee in his return is no longer determinative of the assessee 's tax liability becomes in law it stands superseded by the assessment order. The appeals are dimissed with costs. H.S.K. Appeals dismissed.

The assessee while computing his net wealth claimed a deduction in respect of debts which included amounts representing estimated liabilities on account of income tax	 wealth tax and gift tax. The Wealth Tax Officer rejected the claim on the ground that as those liabilities were claimed on the basis of an estimate they could not be regarded as debts owed on the valuation date. In appeal the Appellate Assistant Commissioner allowed part of the deductions claimed. The Revenue 's appeal to the Appellate Tribunal was dismissed. On a reference being made the High Court held against the Revenue. In this Court the Revenue contended that on a true construction of sec. 2 (m) of the Wealth Tax Act defining the expression "net wealth" the tax liability disclosed by the assessee in his returns should. be taken as representing the debts owed by the assessee on the valuation date. Dismissing the appeals	 ^ HELD: It is settled law that an income tax liability becomes crystallized on the last day of the previous year corresponding to the particular assessment year	 and a wealth tax liability becomes crystallized on the valuation date corresponding to the particular assessment year. In each case the liabilities are perfected debts on the last day of the previous year or the valuation date	 as the case may be. Likewise	 a gift tax liability becomes crystallized	 and therefore a perfected debt	 on the last day of the previous year relevant to the particular assessment year. [487 F G; 488 A] Kesoram Industries and Cotton Mills Ltd. vs Commissioner of Wealth Tax (Central)	 Calcutta; 	 ; H.H. Setu Parvati Bayi vs Commissioner of Wealth Tax	 Kerala	 ; and Commissioner of Wealth Tax	 Madras vs K.S.N. Bhatt	 Civil Appeals Nos. 384 to 387 of 1978	 Judgment delivered on October 21	 1983 referred to. When	 in the course of a wealth tax assessment	 the assessee makes a claim to deduction on account of income tax	 wealth tax and gift tax liabilities 486 subsisting as debts owed by him on the valuation date	 it is the final quantification of the particular tax liability which must be taken into account. Where the wealth tax assessment so made is carried in appeal	 there is no doubt that the appellate authority will take into account the ultimate quantification of the tax liability even though such ultimate quantification has been reached after the relevant valuation date and during the pendency of the wealth tax appeal. [488 F G]