Judgment

DUA, J.:- The Colaba Land and Mills Co., Ltd., (in liquidation) was ordered by the Bombay High Court on October 7, 1959 to be wound up under the provisions of the Companies Act, 1 of 1956 and the Official Liquidator was appointed its liquidator. Earlier on May 1, 1959 the Official Liquidator had been appointed by the High Court its provisional liquidator. On August 23, 1966 the Income-tax Officer (Companies Circle) concerned issued six different notices under S.148 of the Income-tax Act, 1961 proposing to reopen the assessment of the Company and to re-assess it in respect of the assessment years 1950-51 to 1955-56. On December 31, 1966, the Income-tax Officer served further notices under S. 142(1) of the Income-tax Act upon the official Liquidator calling upon him to produce accounts and documents specified at the back of the notices and to furnish any information called for by the said officer. At the foot of the said notices it was stated that failure on the part of the official Liquidator to comply with the terms of those notices would not only result in ex parte assessment against the Company but might also entail penalty under S. 271 of the Income-tax Act. Certain nego