RAJAGOPALA AYYANGAR, J.

M.C.T.M. Corporation Private Ltd., the petitioner before us, was incorporated as a private limited liability company in Pudukottai State. The Income-tax Officer of Pudukottai assessed the petitioner for the assessment year 1951-52 on the basis of a total income of Rs. 3, 66, 260 and issued a demand for the appropriate tax due. This order was passed on March 31, 1954. The validity of this assessment or demand is not now in controversy. Subsequently by a communication dated March 13, 1956, the Income-tax Officer issued notice to the petitioner under section 35 of the Act to show cause why this assessment should not be rectified by the addition of a further sum of Rs. 15, 104-2-0 to the tax as ascertained by order dated March 31, 1954, the addition being stated to be interest chargeable under section 18A(8) of the Income-tax Act, which by mistake had been omitted to be included. The petitioner objected to the proposed rectification on several grounds to the details of which we shall refer presently. But these objections were overruled and a sum of Rs. 10, 591-3-0, this representing the correct figure for interest, was added to the tax demand by an order dated March 29, 1956. Against this order the petitioner preferred a revision under section 33A to the Commissioner of Income-tax but this having been rejected the present petition has been filed for the issued of a writ of certiorari, disputing the legality of the addition. The case of the petitioner before the departmental authorities and before us was twofold : (1) that the petitioner was not bound to have submitted a return of his estimated income under section 18A(3) of the Act and to have paid the appropriate tax due thereon, with the consequence that it was not chargeable with interest under section 18A(8) of the Act. This was rested primarily on the ground that the petitioner had been assessed to tax under the provisions of the Indian Income-tax Act before the assessment year 1951-52, and that this took it out of the operation of section 18A(3); (2) and that if the advance tax was payable by it, still the failure to include it in the final assessment order dated March 31, 1954, was not a mistake of the type which could be rectified under section 35 of the Act. In view of these arguments it is necessary to set out the material portions of section 18A of the Act :"18A. (1)(a) In the case of income in respect of which provision is not made under section 18 for deduction of income-tax at the time of payment, the Income-tax Officer may, on or after the 1st day of April, in any financial year, by order in writing, require an assessee to pay quarterly to the credit of the Central Government on the 15th day of June, 15th day of September, 15th day of December and 15th day of March in that year, respectively, an amount equal to one quarter of the income-tax and super-tax payable on so much of such income as is included in his total income of the latest previous year in respect of which he has been assessed, if that total income exceeded the maximum amount not chargeable to tax in his case by two thousand five hundred rupees. Such income-tax and super-tax shall be calculated at the rates in force for the financial year in which he is required to pay the tax, and shall bear to the total amount of income-tax and super-tax so calculated on the said total income the same proportion as the amount of such inclusions bears to his total income or, in cases where under the provisions of sub-section (1) of section 17 both income-tax and super-tax or super-tax are chargeable with reference to the total world income, shall bear to the total amount of income-tax and super-tax which would have been payable on his total world income of the said previous year had it been his total income the same proportion as the amount of such inclusions bears to his total income :......

(2) If any assessee who is required to pay tax by an order under sub-section (1) estimates at