1. This is a petition under articles 226 and 227 of the Constitution filed by Roshan Lal Kuthiala challenging the legality of a notice dated January 30, 1963, issued by the Income-tax Officer for the payment of advance tax under the provisions of section 210 of the Income-tax Act, 1961.

2. According to the allegations of the petitioner, on December 31, 1962, the Income-tax Officer, Special Investigation Circle, Ambala, respondent, had passed an assessment order for the year 1958-59 purporting to be under section 23 (3)/34 of the Indian Income-tax Act, 1922, and had issued a demand notice for the payment of Rs. 2,66,794.32 nP. on an income of about Rs. 3,13,630. On January 30, 1963, the said Income-tax Officer issued a notice for the payment of advance tax under section 210 of the Income-tax Act, 1961, requiring the petitioner to pay by March 1, 1963, a sum of Rs. 2,32,081 determined to be payable for the financial year 1962-63 on the basis of the assessment order dated December 31, 1962. Since this notice was illegal, the petitioner made representations to the Income-tax Officer and the Commissioner of Income-tax, but without any result. This led to the filing of the presen