1. Division Bench of this Court has doubted the correctness of the decision in Income-tax Officer. B-Ward Companies Circle, Ernakulam v. Official Liquidator, Swaraj Motors (P) Ltd., (134 ITR. 132) and that is why this case has come up before a Full Bench.

2. The Palai Central Bank Ltd., (in liquidation) (hereinafter referred to as the Company) was assessed to Income-tax for the years 1975-76 and 1976-77, allowing permissible deduction to the extent only of Rs. 7,500/-for each year as against the claim of the Official Liquidator for much larger deductions. In appeal by the Official Liquidator, the Appellate Assistant Commissioner allowed the deductions claimed and the taxable income of the Company in liquidation was reduced considerably. In further appeal at the instance of the Department, the Income-tax Appellate Tribunal set aside the orders of the Appellate Assistant Commissioner and allowed deduction to the extent of Rs. 10,000/ -for each year. Fresh demands were made by the Income-tax Officer for payment of the tax assessed in pursuance to the orders of the Tribunal and the entire tax demanded was paid by the Official Liquidator on 27-4-1981. Thereafter fresh notices