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20. The. argument of Mr. Sorabjee is that the expression "capital value of assets" in Entry 86 does not signify the same thing as not wealth as defined in Wealth Tax Act. For calculating the 'capital value of assets' only the encumbrances which are charged on the assets, can be deducted from the market value of the assets, and not the general liabilities of the individual owning the assets, which are to be taken into account for the purpose of wealth-tax. Adopting the observations of HJ. Kania, J. (as he then was) in Sir Byramjee v. Province of Bombay, AIR 1940 (Bombay) 65 at 75, it was asserted that under Entry 86, 'the tax should be on the total capital assets and not on individual portions of a person's capital". In Sir Byramjee's case the relevant entry was Entry 55 in List I of the Government of India Act, 1935, similar to the present Entry 86. The learned counsel pointed out that Bombay decision was approved by the Federal Court in.' Ralla Ram v. Province of East Punjab, AIR 1949 FC 81. Reference was also made to the judgment in Municipal Corporation v. Gordhandas, AIR 1954, Bombay 188 at 194. In support of his stand that Wealth Tax Act is covered by Entry 86 Dr. Gauri Shanker took us through the background in which the Wealth Tax Act was enacted. He placed before us the legislative practice in other countries also as reported by OECD Committee on Fiscal Affairs and the discussion by Kaldor in his book "Indian Tax Reforms". Dealing with the deductions which are allowed under the Wealth Tax Act for liabilities and debts, the learned counsel proceeded to say that is the methodology of levy of this form of capital taxation adopted interna- tionally. Paragraph 1.39 of the OECD Committee's Report stated that "Just as all assets to which a value can be attached should in principle be included in the tax base, so in principle all debts should be deducted from the taxpayer's assets, in order to arrive at his net wealth."