R.P.Sethi, J.

1. The concept of imposition of tax is as old as the human civilisation is. Tax in one form or the other was collected by all forms of Government for providing protection, security and other amenities to the citizens. It is compulsory acquisition of property by the State ostensibly on behalf of the assessee, for the purpose of providing amenities and looking for the vital interests of the society. Even in primitive times the process of compulsory acquisition of the property of the subjects was reserved to if not in cash positively in kind. However, with the development of the concept of the State ways and means of acquisition of the property for the benefit of the State have undergone a sea change. Human instinct has always been at work to avoid the payment of the tax compulsorily resorted to by legal and other means with antagonistic approach adopted both by the State and the assussee of levy and collection of tax which is in existence in all the countries of the world from the days of the known history. In India also, the existence and inception of system of taxation is referred to by Manu in his Manusmriti which prescribes how a duty is to be imposed on the