Judgment

SHAH, J. : M/s. Kantamani Venkata Narayana and Sons-hereinafter referred to as the assessee, is a Hindu undivided family which was assessed to tax on income derived principally from money-lending. In the course of proceedings for assessment of a private limited company styled "Motu Industries Ltd.", the Income-tax Officer Rajahmundry discovered that there was a large accretion to the wealth of the assesses which had not been disclosed in proceedings for its assessment. On March 12, 1959, the Income-tax Officer issued a notice seeking to reopen the assessment for the year 1950-5l . The assessee filed a return under protest. On March 14, I960 the income-tax Officer issued notice of re-assessment for the year 1951-52, and on December 19, 1960, the Income-tax Officer intimated the reasons that had prompted him to issue the notices of re-assessment. On March 24, 1962 the Income-tax Officer issued notices under S. 34 for re-assessment of income of the assessee for the years 1940-41 to 1949-50. The assessee then presented petitions in the High Court of Andhra Pradesh for writs of prohibition directing, the Income-tax Officer to refrain from proceeding in pursuance of the notices