Judgment

HEGDE, J.:- These appeals by certificate raise a common question of low namely whether the essessees (respondents in these appeals) have been properly served before action was taken under Section 33-b of the Indian Income-tax Act. 1922 which will be hereinafter referred to as the Act .

2. The assessment years with which we are concerned in these appeals are 1959-50, 1960-61 and 1961-62. The assessment for those assessment years was completed by the Income-tax Officer on 28-11-1961. Thereafter the Commissioner of Income-tax initiated proceedings under Section 33-B and issued notices to the assessees on 19-10-1963. Notices were issued by registered post. They were also entrusted to the Income-tax Inspector for personal service. It is conceded that the notices sent to the assessees by registered post were served long after the Commissioner passed his orders under Section 33-B. He passed those orders on November 2, 1963 and the notices sent by registered post were only served on the assessees on November 18, 1963. Therefore, we can ignore those notices.3, Now coming "to the notices sought to be served personally by the Income-tax Inspector Mr. Neogi, we have two reports of his