Judgment

BHARGAVA, J. : The assessee in the proceedings out of which this appeal has arisen was Bidhu Bhushan Sarkar, who died and is now represented in these proceedings through his legal representative. The assessee used to be assessed by the Income-tax Officer of District 24 Parganas in Bengal. For the assessment year 1947-48, the assessee filed a voluntary return before the Income-tax Officer on December 22, 1947, showing a net loss of Rs. 330. This return was filed without any notice under S. 22 (2) of the Income-tax Act having been served on him. Before any proceedings could be completed on that return, there was change in territorial jurisdiction and as a result, the assessee s place of business came within the jurisdiction of the Income-tax Office District I (2), Calcutta. In this Income-tax Office, there were a number of Income-tax Officers. The senior-most Income-tax Officer used to be designated as Income-tax Officer, District I (2) and was treated as the principal Income-tax Officer (hereinafter referred to as "the P. I. T. O."). Since there were a number of Additional Income-tax Officers, there was distribution of jurisdiction, and the case of the assessee fell within t