Judgment

PATHAK, J.:- These appeals by special leave are directed against the judgments and orders of the Bombay High Court at its Nagpur Bench dismissing two writ petitions filed by the appellant.

2. The appellant is a sterling company which exports manganese extracted from its manganese mines situated in the States of Maharashtra and Madhya Pradesh. It held these manganese mines up to June 30, 1962. On June 8, 1962 it entered into an agreement with the Government of India under which all the manganese mines except one were transferred to a new company, the Manganese Ore (India) Limited, Nagpur in which the Central Government, the Governments of Maharashtra and Madhya Pradesh and the appellant had shares.

3. The appellant was assessed to income-tax for the assessment year 1967-68, the relevant previous year being the year ended December 31, 1966. Interest under sub-sec. (8) of Sec. 139 of the Income-tax Act, 1961 amounting to Rs. 56,391/- and interest under Sec. 215 of that Act amounting to Rs.9,42,336/-, subsequently reduced to Rs. 5,07,880/- were levied against the appellant. According to the appellant there was ample and clear justification for the delay in furnishing the return u