This is a petition under Article 226 of the Constitution. The petitioner prays for the issue of a writ of mandamus or any other appropriate writ, order or direction, directing the Fourth Income-tax Officer, City Circle V, the first respondent, to forbear from collecting from it the sum of Rs. 20,000 in pursuance of his notices under section 46 (5-A) of the Indian Income-tax Act dated 18th June, 1959 and 21st March, 1961.

The facts are, briefly, as follows. The petitioner is a firm carrying on business as producer of films. The first respondent issued a notice to the petitioner on 18th June, 1959, under section 46 (5-A) of the Income-tax Act stating that it had engaged the services of certain T. S. Baliah, a cine artiste, and, that the remuneration payable by the petitioner to Baliah stood attached and that it should be credited to the Government as he was in arrears of income-tax to the extent of about Rs. 46,819-15. The petitioner sent a reply on 26th June, 1959, and submitted that it had not engaged Baliah for acting in any film produced by it and that there was no subsisting service agreement between them. The Department did not send any further notice as apparentl