Judgment

S. K. DAS, J. : These four appeals brought by the Income-tax Officer, Special Circle, Bangalore, on a certificate granted by the High Court of Mysore, are from the judgment and order of the said High Court dated March 22, 1955, by which it quashed certain proceedings initiated, and orders of assessment made, against the respondent assessee in the matter of reassessment of income-tax for the years 1945 46, 1946-47, 1947-48 and 1948-49.

2. The relevant facts are these. The respondent K. N. Guruswamy was carrying on business as an Excise Contractor in the Civil and Military Station of Bangalore, hereinafter called the retroceded area, in Mysore. He was assessed to income-tax for each of the four years mentioned above under the law then in force in the retroceded area by the Income-tax Officer having jurisdiction therein. For 1945-46 the original assessment was made on February 12, 1946, for 1946-47 on January 21, 1949, for 1947-48 on January 22, 1949, and for 1948-49 also sometime in the year 1949. The tax so assessed was duly paid by the assessee. On January 5, 1954 more than four years after , the Income-tax Officer, Special Circle, Bangalore, served a notice on the assessee