It was urged, however, that Rule 8-A is framed in exercise of the power reserved under s. 26 of the Abolition Act to effectuate the provisions of cl. ( d) of s. 6, and adjustment under the Rule can only be made in respect of agricultural income-tax payable for any 'period prior to the date of vesting. The scheme of the Act, it was said, is that notwithstanding the vesting of the estate in the State by s. 6, arrears of land revenue or other dues and agricultural income-tax continue to remain recoverable and ~ amount so continuing to remain recoverable is liable under the Rules to be adjusted against compensation payable for compulsory termination of the rights of the intermediary. Relying upon the clause "an arrear on account of tax on agricultural income assessed under the U.P. Agricultural Income Tax Act, 1948 for any period prior to the date of vesting" in s. 6 ( d) it was urged that even if under s. 3 of the U.P. Agricultural Income Tax Act, 1948, tax is recoverable on the total agricultural income of the previous year, it is still tax due for the year of assessment and therefore tax assessed on the respondent for the period July 1, 1952 to June 30, 1953, does not fall within the terms of s. 6(d) of the Act and resort cannot be had to Rule 8-A for claiming adjustment of liability to pay tax against the amount of compensation.· We are unable to accept this plea. Section 3 of the U.P. Agricultural Income-tax Act emphatically charges the total agricultural inC<liJle of the previous year to tax. It is true that assessment under the Act is made after the close of the previous year, but the income which is liable to tax is the income of the previous year. The Legislature has unambiguously expressed its intention to impo<e liability to char$e a~cultural income of the_yrevious year. The tax assessed is therefore for the period of the previous year i.e.., for the period which ended OIJ June 30. 1952. The case clearly fell within the terms of s. 6(d) and the benefit of Rule 8-A was admissible to the respondent.
