Judgment

SHAH, J. : This is a group of three appeals filed with certificate of fitness under Art. 132 of the Constitution issued by the High Court of Judicature, Orissa.

2. The Legislature of the Province of Orissa enacted the Orissa Agricultural Income-tax Act, XXIV of 1947 - hereinafter referred to as the Act - providing for the levy of income-tax on agricultural income derived from lands situated in the Province of Orissa. This Act was brought into operation from July 10, 1947. By S. 3, agricultural income-tax at the rate or rates specified in the schedule was made payable for each financial year on the total income of the previous year of every person. By the proviso to that section, agricultural income of the Central Government or of the State Government or of any local authority was exempt from taxation. Section 2, cl. (i) defined a "person as inclusive of a Ruler of an Indian State. The appellant in these three appeals is the former Ruler of the State of Sonepur. After the establishment of the Dominion of India on August 15, 1947, the appellant as the Ruler of the State on Sonepur executed an instrument of accession to the Dominion restricted to three subjects - Defence, Ext