Judgment

GROVER, J.:- The respondent company which is an assessee was required by the Income-tax Officer by notices issued under Sec. 18-A (1) of the Indian Income-tax Act 1922, hereinafter called the "Old Act" to make an advance payment of tax amounting to Rs. 3,17,077 for the assessment year 1960-61 and Rs. 3,54,911 for the assessment year 1961-62. The assessee chose to file its own estimate of tax under Section 18-A (2) and in accordance therewith it paid two instalments of advance tax of Rs 38,333/each for the assessment year 1960-61 and three instalments of Rs. 12,875/- each for the assessment year 1961-62. Thereafter the assessee filed revised estimates of tax in the month of March 1960 and March 1961 respectively estimating the tax at Rs. 1,80,000/- for each of the assessment years on a total income of Rs. 4 lakhs. The balance of advance tax as per its revised estimate was paid in time after deducting the instalments which had already been paid. The assessee subsequently filed its returns of income for the aforesaid two years declaring the total income of Rs. 4,53,942/- and Rupees 7,02,383/respectively. The Income-tax Officer completed the assessment of total income of Rs 5,3