JUDGMENT

B.P. Jeevan Reddy, J.-These appeals are preferred by Marshall Sons and Company (India) Limited (hereinafter referred to as the "Holding Company") as successors to Marshall Sons and Company (Manufacturing) Limited (hereinafter referred to as the "Subsidiary Company") against the judgment and order of the Madras High Court dismissing the writ petitions filed by them. The matter arises under the Income Tax Act.

2. The Holding Company had its registered office at 33-A, Chowranghee Road, Calcutta while the Subsidiary Company had its registered office at Madras. For the purposes of assessment under the Income Tax Act, while the accounting year of the Holding Company was the year ending on 30th June, the accounting year of the Subsidiary Company was the calender year. On Ist December, 1982, two letters were addressed by the Subsidiary Company to the Income Tax Officer stating that the company is desirous of effecting a change in the accounting year. They stated that they would wish to close their accounts of June 30, 1983 for the eighteen months period (January 1, 1982 to June 30, 1983) instead of closing the accounts on December 31, 1982. It was also stated that since the account