Judgment

MAHAJAN C.J.I. The petitioner in this matter is a resident of Akola in the State of Madhya Pradesh and carries on business in various lines i.e., oil mills, banking money lending, etc. It is alleged that during the war years he made huge profits but evaded payment of tax. In the year 1948 the Central Government acting under Section 5(1) of the Taxation on Income (Investigation Commission) Act. 1947, referred his case to the Investigation Commission for investigation and report, in respect of the profits made by him during the period commencing with 1st of January 1939 and ending on 31st of December 1947.

The Commission, after investigation, reported on the 28th of February 1951 that the income of the petitioner concealed and withheld from taxation was in the sum of Rs. 27,25,363 / and the tax payable by him amounted to Rs. 18,44,949/-.

2. During the pendency of the investigation the petitioner applied for settlement under the provisions of Section 8-A of Act XXX of 1947. This application was forwarded along with the report by the Commission to the Central Government. In the settlement application the applicant proposed that he was prepared to pay the sum of Rs. 18,44,949/- as