JUDGMENT

JAGANMOHAN REDDY, J.:—We have heard the learned Additional Solicitor-General who assails the judgment of the High Court and prays that special leave be granted. We, however, do not consider the point arising in the judgment requires examination but as it affects a large number of cases, we have been invited to give our reasons for dismissing the petition. Accordingly, we do so.

2. The main question on which the High Court decided and which is the only question urged before us for admitting the petition is that the word issued occurring in Sec. 18 (2A) of the Wealth-tax Act means served . This decision is well supported not only by the decisions of the High Court but also of this Court. In Banarsi Debi v. Income Tax Officer, Calcutta, 53 ITR 100 this Court observed that the expressions issued and served are used as inter-changeable terms and in the legislative practice of our country they are some times used to convey the same idea. Accordingly, it was held that the word issued was not used in the narrow sense of sent but that the said expression had received before the Indian Income-tax (Amendment) Act, 1959, 1151 a clear judicial interpretation. Subba Rao, J. as