1. One wishes that S.178 of the Income-tax Act, 1961 were more explicit, but, as I read that provision, I do not think that it affects the scheme of priority in S.530 of the Companies Act although its effect no doubt is that the amount set aside under sub-section (3) thereof has first to be applied to the satisfaction of the tax liability and in that sense the tax liability gets priority over the other debts of the company in the same way as a secured creditor who stands outside the winding up, or whose security is redeemed under sub-section (4) of S.47 of the Provincial Insolvency Act read with S.529 of the Companies Act, gets priority to the extent of the value of his security. But, although sub-section (3) of S.178 of the Income-tax Act, which speaks of the liquidator making "payment to secured creditors whose debts are entitled under law to priority of payment over debts due to Government" the only payment I can think of by the liquidator to a secured creditor who has not relinquished his security is a payment under sub-section (4) of S.47 of the Provincial Insolvency Act, or to a creditor who, although he has not relinquished his security, has agreed to the liquida