Judgment

GROVER, J.:- The points involved in all these appeals by certificate are common and relate primarily to the true scope and interpretation of certain provisions of the Expenditure Tax Act 1957, as amended by the Finance Act, 1959, hereinafter called the Act .

2. The facts in C. As. 1794-1796/67 may be stated. Prince Azam Jha Bahadur the eldest son of the Nizam of Hyderabad filed returns for the purpose of assessment of Expenditure Tax for the assessment years 1959-60, 1960-61 and 1961-62.

The assessment were completed as follows:

1959-60 completed on 27-3-1961.

1960-61 completed on 22-12-1961.

1961-62 completed on 25-1-1962.

On May 5, 1962 the Expenditure Tax Officer issued notices under S.16 of the Act calling upon the assessee to file supplementary returns for the three years in question on the ground that he had reason to believe that assessee s expenditure had escaped assessment or had been under-assessed. The supplementary returns were filed on March 16, 1962 declaring the same expenditure as shown in the original returns. It appears that the assessee or the assessee s representative was informed by the Expenditure Tax Officer that the assessments had been reopened for in