Judgment S.K.Jha, J. 1. As directed by this Court, a statement of case has been submitted by the Income Tax Appellate Tribunal, B Bench, Patna, under Sec.27(3) of the Wealth-tax Act 1957 and the following question of law has been referred for the opinion of this Court: Whether on the facts and in the circumstances of the case and in view of the alleged circular dated 14.2.1974 issued by the Central Board of Direct Taxes, referred to in the order of the Tribunal, the Tribunal was justified in law in holding that the Income-tax liability of Rs. 5,88,000 under Sec. 68 of the Finance Act, 1965 was a debt owed on the relevant valuation date that is, 15.11.64, and on that basis in allowing the same as deduction in computation of the assessees net wealth. 2. The assesses is an individual. The case relates to the assessment year 1964-65. The Wealth-tax Officer passed an order on 31.8.1970 under Sec.17 of the Wealth Tax Act, 1957 , bringing to tax the value of premium prize bonds worth Rs. 9,80,000/-. The assesses claimed before the Wealth-tax Officer that in the recompilation of his net wealth, a sum of Rs. 5,88,000/-being the income-tax liability attributable to the additional sum of Rs. 9,80,000.00 brought in to tax under Sec.17 should be deducted as a debt by him on the relevant valuation date which was 15.11.1963. The assesses had disclosed on 31.5.1965 that he had been owing premium prize bonds worth Rs. 9,80,000/-. The Wealth-tax Officer did not allow the claim, as according to him it was not an admissible deduction. On further appeal, the Appellate Assistant Commissioner by his order dated 16.11.1971 held that the Income-tax liability claimed by the assesses was an admissible deduction and so he allowed the claim by his order in appeal Nos. 88 and 87 C.C.D. of 1970-71. 3. The Department appealed to the Tribunal against the aforesaid findings of the Appellate Assistant Commissioner. The Tribunal considered the contentions of the Department and found that the decision in the case of Vijay Kumar Behel 81 I.T.R. 202 was based on the principle laid down by the Supreme Court in the case of Keshoram industries 59 I.T.R. 767, which was not noticed in the case of C.K. Babu Naidu 82 I.T.R. 410. The Tribunal considered the contentions of the Department and found that the decision in the case of Vijay Kumar Behel 81 I.T.R. 202 was based on the principle laid down by the Supreme Court in the case of Keshoram industries 59 I.T.R. 767, which was not noticed in the case of C.K. Babu Naidu 82 I.T.R. 410. The Tribunal accordingly held |that the Appellate Assistant Commissioner rightly allowed the Income-tax payable on the disclosed wealth as deduction in the computation of the assessees net wealth. The appeal filed by the Department was accordingly dismissed. 4. In the appellate order, the Tribunal observed as follows: The valuation date in this case is 15.11.63. The assesses disclosed oh 31.5.65 that he had been owing the premium prize bonds worth Rs. 9,80,000. The Wealth-tax Officer reopened the assessment for the year 1964-65 and reassessed the net wealth on 31.8,70 including the sum of Rs. 9,80,000. The assesses claimed the tax of Rs. 5,88,000 payable on the said Rs. 9,80,000 as deduction from the computation of net wealth. The question before us is whether this claim was rightly allowed by the Appellate Assistant Commissioner. We find conflicting views of the High Courts on this question. Thereafter a reference was made to the cases of C.K.B. Naidu (Supra). Vijay Kumar Behel (Supra) and numerous other decisions. The Tribunal after carefully considering the issue involved followed the decision in the case of Vijay Kumar Behel (Supra). The Tribunal accordingly held that the Appellate Assistant Commissioner rightly allowed the income-tax payable on the disclosed wealth as a deduction in the computation of the assessees net wealth. 5. It is worthwhile to mention that with regard to this very assesses for the assessment year 1965-66, a similar question was referred to this Court and this Court in the case of Commissioner of Wealth Tax V/s. Shivram Singh (1979) 8 C.T.R. (Pat.) 345, upheld the view of Tribunal and held as follows: If the assesses had put forth a claim for debt owed in shape of income tax on an asset which was yet to be disclosed and offered for taxation, such liability would have been a contingent liability. In the instant case, however, the assets have been brought to surface and have also suffered taxation. In the instant case, however, the assets have been brought to surface and have also suffered taxation. Though the disclosure was made on the 31st May, 1965, that is, after the relevant valuation date, the department thought and rightly so that the assets had been with assesses even on the relevant valuation date. It therefore follows that on the said valuation date, the assets were held under a liability to pay income-tax oh them. It further follows as a natural corollary that there is a perfected debt on the valuation date, in the shape of income-tax payable on the said assets, against the assesses. The Department, having included the value of the said assets in the assessees total wealth as on the relevant valuation date, cannot turn back and sky that it would not deduct the debt owed on it because the actual date of its acquisition was unascertainable. It was accordingly held that the assesses was entitled to the deduction of the income-tax payable on the assets voluntarily disclosed by him under Sec. 68 of Finance Act, 1965. 6 The view is further fortified by a decision of the Supreme Court in the case of Ahmed Ibrahim Sahigra Dhoraji 129 I.T.R. 314, wherein it was held that the declaration made under Sec. 68 of the Finance Act, 1965 was dependent upon the volition of the declaring and that the liability to tax on the amount mentioned therein was contingent upon the willingness of the declaring to disclose the amount make no difference. Any such voluntary disclosure by an assesses, even in the absence of Sec. 68, would have exposed him to an assessment or reassessment, as the case may be, being made in respect of the sum disclosed as part of the income of the relevant assessment year and with additional liability to payment of interest and levy of penalty and perhaps with the right to claim deductions, if any, admissible in the circumstances of the case and the benefit of other procedural rights. The voluntary character of the declaration cannot, therefore, alter the character of the tax. The voluntary character of the declaration cannot, therefore, alter the character of the tax. It was further held that irrespective of the other income which may have been determined in an ordinary proceeding under the relevant law of income-tax, a fixed rate of tax is payable under Sec. 68(3) and hence the amount disclosed being treated as the income of any particular year would not make any difference regarding the quantum of tax, nor is there any other purpose to be served by such allocation. Section 68 is in the nature of a package dealt but the net result achieved is that the declaring is treated as having discharged all his liability in respect of the said income under the income-tax law. Therefore, the amount declared under Sec. 68 of the Finance Act, 1965 has the liability to pay income-tax imbedded in it on the valuation date but only the ascertainment of that liability is postponed to a future date. In the case of concealed income disclosed under Sec. 68, its determination is allowed to be done in accordance with the provisions of Sec. 68. Even though it may appear to be by itself a complete code, it is only a scheme which provides a method for the liquidation of an already existing-income-tax liability which was present on the relevant valuation date. 7. The Department had relied upon a decision of the Gujarat High Court in the case of C.W.T. V/s. Ahmed Ibrahim Sahigara -- . That decision of the Gujarat High Court was reversed by the Supreme Court in 129 ITR 314 (Supra). 8. We accordingly find that the Tribunal was perfectly justified in law in holding that the income-tax liability of Rs. 5,88,000.00 under Sec. 68 of the Finance Act was a debt owed on the relevant valuation date, that is, 15.11.1963 and on that basis the allowance of the same as a deduction in computation of the assesses net wealth was fully justified. We accordingly answer the question referred to up in the affirmative in favor of the assesses and against the Department. The assesses shall be entitled to his costs. Hearing fee is assessed at Rs, 250.00 only.