ORDER P.V. Dixit, C.J. This is an application unders 226 and 227 of the Constitution filed by the ex-proprietor of Bhadra Zamindan which was an estate under Section 2(3) of the C. P. Land Revenue Act. On the abolition of proprietary rights under the Madhya Pradesh Abolition of Proprietary Rights (Estates, Mahals, Alienated Lands) Act, 1950, the Compensation Officer deter-mined the compensation payable to the Petitioner at Rs. 2,21,330 12 6. The compensation payable to the applicant under the Act and the rules contained in Schedule I of the Act is ten times the net income of the estate determined in accordance with the rules in Schedule f Under Rule 2(2)(c) the net income of an estate is required to be calculated by deducting from the gross income inter alia the amount constituting "the average of the income-tax paid in respect of the income received from big forest during the period of thirty agricultural years preceding the agricultural year in which the relevant date falls". In arriving at the "average of the income-tax" for the purpose of deduction, the Compensation Officer took into account the amount of super tax also paid by the Petitioner in the relevant thirty agricultural years. According to the Petitioner, the average of the income-tax paid by him during the material thirty years was only Rs. 3,760-2-9, that the average calculated by the Compensation Officer after including super tax was Rs. 7,070-8-0, that thus the net income of the estate was lowered by an amount of Rs, 3,310-5-3; and that consequently he was deprived of an amount of compensation equivalent to ten times the difference viz. Rs. 3,310-5-3. The Petitioner contends that the amount of super tax paid by him during the material thirty agricultural years was not "income-tax paid in respect of the income received from big forest" and it could not, therefore, be taken into account while calculating the average of the income-tax for deduction purposes. He, therefore, prays that a writ quashing the order of the Respondents dealing with this deduction be issued and an appropriate direction be given to them for computing the net income after making deduction under Rule 2(2)(c) only on account of the income-tax. In our opinion, the permissible deduction under Clause (c) of Sub-rule (2) of Rule 2 of Schedule I of the Act is only on account of income-tax and not on account of any super tax. In our opinion, the permissible deduction under Clause (c) of Sub-rule (2) of Rule 2 of Schedule I of the Act is only on account of income-tax and not on account of any super tax. This is clear from the wording of the clause and the concept of income tax and super tax under the Indian Income-tax Act. Clause (c) speaks of deduction of the "average of the income-tax paid in respect of the income" received from big forest. The words "in respect of" are significant. They obviously mean that the income-tax paid must have direct nexus with the forest income. A remote connection is not enough. Now under Section 55 of the Income-tax Act, super tax is no doubt "an additional duty of income-tax at the rate or rates laid down for a particular year by a Central Act". But this additional duty of income-tax, as the opening words of Section 55 say, is charged, levied and paid for the material year "in respect of the total income of the previous year" (underlining is ours). Super tax is imposed on total income when it exceeds a specified amount. For the purpose of super tax it is the total income of any Assessee from all sources that has to be taken into account. It is a tax in respect of the total income of the Assessee and not in respect of the income received from any particular source. Thus where super tax is charged and levied on the total income of the Assessee, it cannot be said that the super tax has a direct connection with income under any particular head in the sense that but for the income under that head the super tax would not have been imposed. Super tax is a tax in respect of the total income. It is not in respect of an income under any particular head though it may be indirectly a tax on the income from that source. Therefore, though income-tax may include super tax for certain purposes, it is clear that in Clause (c) of Rule 2 (2) a distinction has been made between the payment of income-tax and super tax. The reason for this distinction is obvious. Sub-rule (2) of Rule 2 is concerned with the calculation of the net income of any estate after making certain deductions. The reason for this distinction is obvious. Sub-rule (2) of Rule 2 is concerned with the calculation of the net income of any estate after making certain deductions. On general principle, in arriving at the net income from any source only those deductions would be legitimate which have a direct relation with that income. Super tax has no such relation to the income from any particular head. The Legislature therefore thought it fit to exclude it from the scope of Clause (c) of Rule 2 (2). There is also another reason why the expression "the average of the income-tax paid" cannot be taken as including also the average of super tax paid. The Act and the rules are of confiscatory nature and provided for payment of compensation to the proprietors divested of their property. The provisions with regard to compensation must, therefore, be liberally construed and, in case of doubt, in favour of the ex-proprietors. The meaning of the terms 'income-tax' and 'super tax' as used in the Income-tax Act were well understood for several years long before the enactment of the M. F. Abolition of Proprietary Rights (Estates, Mahals, Alienated Lands) Act, 1950. If, therefore, being fully aware of the distinction and concept of super tax and income-tax the Legislature still chose to use the word 'income-tax' to the exclusion of 'super tax', it must be taken that it did not intend to make any deduction on account of super tax paid in the computation of the net income. For these reasons, we are of the view that the Compensation Officer was not right in taking into account the amount of super tax paid by the Petitioner while calculating, for the purposes of deduction under Rule 2(2)(c), the average of the income-tax paid by him in respect of the income from big forest. The order of the Compensation Officer in so far as it relates to this deduction is quashed and he is directed to make a fresh determination of compensation in the light of this order. There will be no order as to costs. The outstanding amount of security deposit shall be refunded to the Petitioner.