Held, allowing the petition the Court held that   the assessee had complied with the requirements of sections 199D and 199E inasmuch as the tax at the rate of 33 per cent., surcharge at the rate of 33 per cent. on the tax and penalty at the rate of 10 per cent. had been received by the Department and credited to the respective authority. It was only 25 per cent. of the penalty which was required to be deposited with the respondent-authorities for a period of four years in terms of section 199F which had not been complied with. This also the assessee sought to comply with by depositing with the bank but was unable to do so. The Department continued to have within its possession a sum of Rs. 14.98 lakhs. The Scheme could have been simplified inasmuch as from and out of the undisclosed amount seized, the amount required to be adjusted under sections 199D, 199E and 199F could have been so adjusted and the balance returned to the assessee as long as the assessee wished to avail of the benefit of the Scheme. Instead of doing so, the Scheme was made burdensome inasmuch as the amount was seized and thereafter, the assessee was required to make payment of tax, surcharge and penalty as also deposit the amount under section 199F in the particular Scheme. This resulted in unnecessary administrative burden and costs. The assessee had tried to deposit the amount by the application in form 2 as required under the Scheme. It was only on account of the bank not accepting the deposit that form 2 could not be got counter signed with an acknowledgment from the bank and submitted to the Department. The assessee had made all efforts to try and comply with the requirement of the Scheme and ought not to be denied the benefit of the Scheme especially when he had stated that he was still willing to deposit the amount for a period of four years from today and would not claim any interest thereon. The respondents were to appropriate the sum equivalent to Rs. 7,50,000 of the amount held by them to the Scheme and return the balance amount of Rs. 7,50,000 to the assessee within 30 days.