Judgement

SIKRI, J.:- On January 24, 1963, the Commissioner of Income-tax, West Bengal, sent the following notice to Smt. Kalawati Harlalka, appellant before us, hereinafter referred to as the assessee :

"Sub: Income-tax assessments of 1952-53 to 1960-61. Assessments erroneous and prejudicial to the interests of revenue - Revision of assessments under Sec. 33B of the Indian Income-tax Act 1922- proposal for- Notice. regarding

"On calling for and examining the records of your case for the assessment years 1952-53, 1953-54, 1954-55, 1855-56, 1956-57, 1957-58, 1958-59, 1959-60 and 1960-61 and other connected records, I consider that the orders of assessment passed by the Incometax Officer D Ward, Howrah, on 7th February, 1961, are erroneous in so far as they are prejudicial to the interest of revenue for the following reasons amongst others.

2. Enquiries made have revealed that no business as alleged was carried on from the address declared in the return. Also the said Income-tax Officer was not justified in accepting the initial capital, the acquisition and sale of jewellery, the income from business, gift made by you etc. without any enquiry or evidence whatsoever.

3. I, therefore, pro