In other words does section 68 impose a new charge on the income of the declarant for the first time wholly independent of the levy under section 3 of the Indian Income tax Act 192 ' or section 4 of the Income tax Act 1961 ? The High 413 Court has given the following reasons for holding that the tax paid under section 68 is not tax on income payable under the Indian Income tax Act 1922 and Income tax Act 1961: (i) the charge under the Income tax Act is on the total income of the previous year and not on any particular item of income but that is not so under section 68,(ii) payment of tax under section 68 has no reference to any assessment year and unless it is correlated to an assessment year it can not be ordinary income tax and (iii) the disclosed income is chargeable to tax without allowing usual deductions and without providing for any procedure for qualification.