(RAMAPRASADA RAO, J.)

The petitioner is one K.A. Meera Saibo. His son swears to the affidavit in support of this application. It is said that the petitioner is carrying on business under the name and style of K.A.M.P. Meera Saibo and Brothers, Kandy, Ceylon. The deponent of the affidavit is a partner in the said Company. In respect of the income earned by the said firm in Ceylon, it is said that the said income was assessed in India to tax for the years 1950-1951 to 1957-1958. Even so, the firms liability to pay income-tax such income was also reckoned. It is said that the income earned in Ceylon was not remitted to India. The assessment proceedings for the years in question were finally concluded for the last year in about January 1964. It is admitted that a major portion of the income on which tax has been levied is relatable to income earned in Ceyeon. In or about, 1947, due to exchange control regulations which came into force in Ceylon, no money could be remitted from Ceylon to India without a permit obtained from the appropriate authorities for such remittance. The petitioners case is that in spite of his best efforts to secure such a remittance on due applications