SRINIVASAN J.

For the several assessment years 1940-41 to 1953-54, the assessee had been assessed to a total tax of Rs. 28.87 lakhs. Out of this the demand for RS. 2.27 lakhs became invalidated by the decision of the Supreme Court relating to the Investigation Commission Act. Of the balance of the liability of Rs. 26.60 lakhs, the assessee had paid Rs. 11.11 lakhs. In April, 1957, the assessee petitioned the Central Board of Revenue pointing out that the liability that had been imposed upon him arose mostly out of estimated additions which were disputed by him. He stated further that the net worth of his properties was only Rs. 6.51 lakhs and that if they were to be sold in realisation of the arrears of tax, the properties would fetch even less. He suggested that the total outstanding liability might be reduced to Rs. 6.50 lakhs and that he would withdraw all his petitions by way of appeals, revisions and the like for the relevant years. He also asked that the sum of Rs. 6.50 lakhs, at which his tax liability should be settled, should be made payable in instalments. This request of the assessee was accepted by the Central Board of Revenue on April 25, 1957. Certain dates