These two appeals by Department relate to asst. yrs. 1979-80 and 1980-81. On relevant valuation dates, assessee held 160 equity shares o f Skefe-Co. India Bearing Co. Ltd. shares of said company were not quoted at stock exchange. Consequently, valuation had to be done in accordance with provisions of r. 1D if WT Rules, 1957 ('the Rules'). assessee in his computation under said rule did not treat amount of advance tax paid by company as asset in accordance with provisions in cl. (i) (a) of Explanation II of r. 1D and further for determining extent of excess over tax payable with reference to book profits under cl. (ii) (e) of said Explanation did not deduct amount of advanced tax paid from amount representing provision for taxation. WTO, on other hand, deducted amount of advance tax paid from amount representing provision for taxation for computing extent excess over tax payable with reference to book profits under cl. (ii) (e). Consequently, whereas value declared by assessee was nil value estimated by WTO came to Rs. 1,026.29 and Rs. 1,375.16 per share for these assessment years, respectively. In appeals filed by assessee, AAC relying on decision of his predecessor for earlier assessment year accepted computation made by assessee. Department has now come in apples before us. assessee did not appear before us. We have heard learned Departmental representative. We find that computation made by assessee is in accordance with principle laid down by Gujarat High Court in CWT vs. Ashok K. Parikh (1981) 129 ITR 46 and CWT vs. Arvindbhai Chinubhai (1981) 24 CTR (Guj) 228: (1982) 133 ITR 800. High Court has held that amount of advanced tax paid should not be treated as asset and that as far as liability is concerned, gross provision for taxation without adjusting of advanced tax paid should not be treated as liability. Benches of Tribunal at Bombay had been following these decisions of Gujarat High Court for number of years. However, now we found that two High Courts have dissented from view taken by Gujarat High Court. Those High Courts are Punjab and Harayana and Karnataka. decisions are Ashok Kumar Oswal vs. CWT (1984) 148 ITR 620 and CWT vs. N. Krishnan (1986) 24 TAXMAN 269. In. T. V. Srinivasan vs. CWT (1985) 152 ITR 599, Madras High Court while considering slightly different question has disapproved view of Gujarat High Court in Arvind Chinubhai's case (supra). In CIT vs. Hoechst Pharmaceutical Ltd. (1984) 39 CTR (Bom) 246: (1984) 149 ITR 94, Bombay High Court while dealing with balance sheet in connection with computation of relief under s. 80J of IT Act, 1961 held that it is only net liability regarding payment of tax which is to be taken into account and as such, if amount of advanced tax paid is treated as assets, gross provisions for taxation should be treated as liability while if amount of advance tax paid is not treated as assets then net liability to pay tax should be treated as liability. same principle would apply while making computation under r. 1D. Since majority of High Courts have taken view different from view of Gujarat High Court, Benches of Tribunal have of late started taking view in conformity with decisions of Punjab and Harayana High Court and Karnataka High Court, in preference to view of Gujarat High Court. In accordance with view which Benches of Tribunal are taking we hold that when amount of advance tax paid is not treated as assets under cl. (i) (a) of Explanation II, provision regarding taxation should be reduced by amount of advance tax paid in order to determine extent of excess over tax payable in accordance with book profits under cl. (ii) (e). computation made by WTO was, therefore, correct while computation made by WTO was, therefore, correct while computation made by assessee was not correct. We, accordingly, set aside orders of AAC and restore that of WTO on this point. In result, appeals are allowed. *** WEALTH-TAX OFFICER v. KAMALJIT SINGH