(1) IN this group of cases common questions arise for determination. They are covered by the decision of this court in J.K. Cotton Spg. and Wvg. Mills Ltd. v. Union of india. By the said decision this court upheld as legal and valid the amendments made to Rules 9 and 49. It was argued that if the amendments are given retrospective effect from the date the rules were framed, i.e., from 28/2/1944, the assessees would be required to pay an enormous amount of duty. This court appreciated the contention that if the duty has to be paid with retrospective effect from 1944 it would undoubtedly cause great hardship to the assessees but concluded that in view of Section 11 -A of the Act such an apprehension was misplaced. Pointing to clause (1 of Section I I-A it held that it engrafts a rule of limitation of six months and since the proviso to Section 11-A is not applicable the demand though it may Include even a demand for more than six months must be made within a period of six months from the date of the amendment.

(2) HAVING considered the facts in this group of cases, in our view, in the light of the observation in J.K. Cotton Spg. and Wvg. Mills it would be appropriate t