The petitioner has challenged the impugned order dated 24.3.2008 passed by the 1st respondent in Application No. TN/CN 01/05-06/5/IT filed by the 2nd respondent on the ground that the 2nd respondent had failed to pay the admitted liability in terms of Section 245D (2A) of the Income Tax Act, 1961. According to the petitioner there was a shortfall in the payment of tax on the admitted liability.