Looks like a 40-41 by numbers but as said a odd frame, I'm only talking about the 3 gill frame and years may not be exact, first yr 38 has straight rear stays straight front down tube, 39-40 has kicked up rear stays and straight front down tube, 41-42 are curved/curved, the bent tank is completely different with multiple frame combinations even the same year but noticed in 41 they had some thrift models that used older frame components so maybe they were using up whatever they had before the war. this is where we need the CWC scholar RMS37 Phil Marshall.