( 1 ) THIS application by the Union of India under Article 227 of the Constitution of India is directed against an order of the Revenue Divisional Commissioner reversing the order of the Tax Recovery Officer in his Certificate Case No. 659-I. T. (A)/68-69. The opposite party, B. C. Nawn and Bros. (P.) Ltd. , was assessed to income-tax under Section 144 of the Income-tax Act, 1961 (to be hereafter mentioned as "the Act" ). The Income-tax Officer, who assessed the tax, served a notice of demand under Section 156 of the Act upon the opposite-party-assessee. The assessee did not pay the assessed tax within the period specified in Section 220 (1 ). He preferred an appeal against the order of assessment before the Appellate Assistant Commissioner under Section 246 and later before the Income-tax Appellate Tribunal under Section 253. On the prayer of the assessee, the Income-tax Officer allowed him, under Section 220 (3), to make an initial payment towards the assessed tax and to pay the balance in a number of instalments There was default by him in the matter of compliance, with that order. The Income-tax Officer then took steps for attachment and sale of the assessee's immovable