Paripoornan, J.

Respondents 1 and 2 in O.P.No. 2379 of 1986 (the revenue) are the appellants herein. The petitioner in the O.P. is the sole respondent herein. He is an assessee to Income-tax. He filed a return for the assessment year 1983-84, wherein he disclosed an amount of Rs.3,11,065/- in Part III of the return, being advance paid to him on 11-3-1983 towards compensation to be yet finally determined in respect of the agricultural land acquired by the Government and which the Government took advance possession on 19-11-1982. The award was passed by the Land Acquisition Officer on 31-3-1984. Deducting the advance amount paid in the sum of Rs.3,11,065/-, a further sum of Rs.4,26,150.58 was paid to the assessee on 30-4-1984. Within six months from the date of the advance payment of Rs. 3,11,065/-, on 26-8-1983 the assessee invested a sum of Rs.3,10,200/- in the three year National Rural Development Bonds (second issue).- The balance of Rs.4,26,150.58, received on 30-4-1984, was invested by the assessee on 28-7-1984 in specified units of the Unit Trust. During the assessment stage, the assessee pleaded that capital gains, if any, which arose by acquisition of the agricult