1. In this case Maharaja Bahadur Ramran Vijay Prasad Singh was assessed to income-tax in the first instance by an order of the Income-tax Officer dated 12-12-1944. The assessee had shown in his return a gross figure of Rs. 87,910 as interest on arrears of rent from the agricultural land. But the Income-tax Officer excluded this amount from the total assessable income on the basis of a Full Bench decision of the Patna High Court holding that the interest on the agricultural income was not liable to be taxed under the Indian Income-tax Act.

The decision of the Patna High Court was reversed by the Judicial Committee some time in the year 1948. The Judicial Committee took the view that interest on arrears of rent was not agricultural income and was liable to be taxed under the provisions of the Indian Income-tax Act.

After the decision of the Judicial Committee was pronounced the Income-tax Officer started a proceeding against the Maharaja under Sec.34. The proceeding was started on 25-9-1948. The provisions of Sec.34 were later amended and though the actual date of the amendment was 8-9-1948 the amendment was made with retrospective effect from 30-3-1948. In view of the amendm