( 1 ) THIS is an application for review of a judgment passed herein by me on the 22nd December, 1960 by which the application was dismissed and the rule was discharged. The facts are shortly as follows: For the income-tax 'assessment year 1945-46 "messrs. Sen and Co. , Proprietor Sri Panna Lal Sen" was found liable to pay a certain sum as arrears of income-tax and a certain penalty was imposed under Section 46 (1) of the Income Tax Act. Thereafter, the Income Tax Officer forwarded to the Certificate Officer, 24 Parganas, a certificate for the said amount and on the 31st March 1955 a certificate was filed by the Certificate Officer, 24 Parganas. In the certificate as filed, there was a clerical error. Notice under Section 7 of the Act was served on the certificate debtor but before he could object Panna Lal Sen died. At the instance of the heirs and legal representatives of Panna Lal Sen, the matter was adjourned from time to time and ultimately an application was made by the petitioner under Section 37 of the Public Demands Recovery Act. This objection was rejected and a rule was taken out from this Court. Various points were taken in support of the application, which ha