Judgment :- BAKTHAVATSALAM, J. The petitioner has come up to this court praying for the issue of a certiorarified mandamus to call for the records of the petitioner on the file of the first respondent TR. Nos. 815 to 819/1984-85 34 to 38/1987-88 and No. 6/11/1989-90 and quash the impugned order dated December 17, 1991, and consequently, direct the respondents to grant the certificate under section 230A of the Income-tax Act, 1961. Notice of motion has been ordered by me on January 6, 1992. Mr. N. V. Balasubramaniam, junior standing counsel for income-tax cases, appears for the respondents. Learned counsel appearing for the respondents on instructions brought to the notice of this court that right from the years 1971-72 to 1988-89, the assessment of tax due is Rs. 32, 93, 250 and the interest due under sections 220 and 199 of the Income-tax Act is Rs. 21, 57, 060 and in all the total arrears is Rs. 54, 50, 310. Mr. P. P. S. Janarthana Raja, learned counsel for the petitioner, contends that, if the respondents-Department gives a certificate under section 230A of the Income-tax Act, it will be easier for the petitioner to sell the property and pay the arrears due. According to learned counsel appearing for the petitioner, it is not necessary for the Government to bring the property to auction ; if the property is sold in auction the value of the property will be very low and, on the other hand, the petitioner can get a very good market value if a certificate is issued under section 230A of the Income-tax Act. According to learned counsel, the petitioner is even prepared to mortgage the property and pay the arrears outstanding as on date as stated above. Learned counsel submits before the court that if the only property of the petitioner is brought to auction and the sale proceeds are allowed to be taken away by the Income-tax Department, it will be much against the interests of the petitioner and if ultimately the interest levied under sections 220 and 199 of the Income-tax Act is waived, the petitioner would not have any remedy at allI have considered the arguments of Mr. P. P. S. Janarthana Raja, learned counsel for the petitioner, and of Mr. N. V. Balasubramaniam, junior standing counsel for the Income-tax Department. P. P. S. Janarthana Raja, learned counsel for the petitioner, and of Mr. N. V. Balasubramaniam, junior standing counsel for the Income-tax Department. I have also perused the statement of accounts produced by learned counsel for the respondents-Department with regard to the arrears due by the petitioner to the Department. Having given due consideration to the arguments of learned counsel on both sides and on a perusal of the affidavit and the relevant materials available, I am not able to agree with the argument of learned counsel for the petitioner that a certificate under section 230A of the Income-tax Act can be issued at this situation. A reading of the section clearly shows that, unless the Income-tax Officer is satisfied with certain conditions which are set out in section 230A of the Income-tax Act, this court cannot direct the respondents-Department to issue a certificate under section 230A of the Act. When construing the provisions of section 230A of the Act, the observation of Rowlatt J. in Cape Brandy Syndicate v. IRC, has to be kept in mind. In the abovementioned decision, Rowlatt J. has observed as follows: ".....in a taxing Act one has to look merely at what is clearly said. There is no room for any intendment. Nothing is to be read in and nothing is to be implied. One can only look fairly at the language used ......" The abovementioned statement of Rowlatt J., has been approved in many cases by the apex court of this land, So, I am not able to accept the arguments of learned counsel for the petitioner that the petitioner should be granted a certificate so as to enable him to sell the property. In my view, such a certificate could not be issued. So, the petitioner herein is praying for an impossibilityComing to the merits of the case, the vendee seems to be the son of the petitioner and the agreement of sale will be for Rs. 14 lakhs. I do not understand how the petitioner is going to clear the entire arrears of income-tax even if a certificate under section 230A of the Income-tax Act is issued to the petitioner. So I am fully satisfied that this court should not interfere with the proceedings at this stage. 14 lakhs. I do not understand how the petitioner is going to clear the entire arrears of income-tax even if a certificate under section 230A of the Income-tax Act is issued to the petitioner. So I am fully satisfied that this court should not interfere with the proceedings at this stage. Learned counsel for the petitioner made a suggestion before this court that the property can be mortgaged and the mortgagee can be asked to pay the amount directly to the respondents Department and that will satisfy the Department in so far as the tax arrears of the petitioner is concerned. The petitioner has come up before this court in W. P. No. 2895 of 1989 and has got an order dated March 22, 1989, passed by S. Ramalingam J., with certain conditions. As stated in the earlier portion of this order, the petitioner has not complied with the said conditions and when the Revenue seeks to recover the arrears, the petitioner, in my view, wriggles out of the situation on some pretext or other. In the interests of the Revenue, it cannot be done. However, when the aforesaid suggestion made by learned counsel for the petitioner is put to learned counsel appearing for the respondents-Department, he fairly states that the petitioner can approach the Commissioner of Income-tax, Madras, with his request which is not at all pleaded before this court by the petitioner in such a manner. Taking into consideration, the facts and circumstances of the case and the fact that there are huge tax arrears to be paid by the petitioner to the Department and also not to deprive the petitioner from getting the present market value for his property, I am of the view that the only course open to the petitioner is to approach the Commissioner of Income-tax, after getting hold of a person who agrees to pay the amount so that once the arrears are paid, the Department may consider the grant of a certificate under section 230A of the Income-tax Act. A Division Bench of this court in T. T. Krishnamachari v. ITO, while considering the scope of issuing a certificate under section 230A of the Act has held that a person cannot claim clearance from the income-tax authorities before the sale is concluded. As such, this should also be taken note of by the respondents-Department when considering the request of the petitioner. As such, this should also be taken note of by the respondents-Department when considering the request of the petitioner. As I have already stated, in the interests of the Revenue as well as to safeguard the interest of the petitioner, a via media can be struck at this point of time, i.e., by asking the petitioner to approach the Commissioner with a concrete proposal of mortgage and a person who is prepared to pay the entire amount of tax arrears to the Department. If it is done, I think the respondents-Department can 'consider the question of granting a certificate under section 230A of the Income-tax Act. As such, though I am not inclined to set aside the proclamation made in this case, to give some time to the petitioner, I direct the third respondent herein to consider the proposal of the petitioner, if the petitioner approaches the Commissioner of Income-tax, the third respondent herein, with the proposal for mortgaging the property, provided the petitioner satisfies the condition of paying the arrears without disputing the quantum as it stands today. As such, instead of granting the prayer as asked for, since this court can mould the prayer to suit the occasion, a direction is to issue to the third respondent to consider the proposal of the petitioner if made by the petitioner as stated above, and pass appropriate orders on or before February 20, 1992. Till then the question of proclamation shall stand stayed ; if there is no proposal, it is open to the respondents to proceed further to realise the arrears. The writ petition is ordered accordingly. However, there will be no order as to costs.