JUDGMENT :

Sikri, J.

1. This appeal by certificate of fitness granted by the High Court is directed against the judgment of the Division Bench of the High Court at Calcutta, affirming the judgment of the Single Judge. This appeal was heard together in this Court alongwith Civil Appeal No. 1421 of 1966 (Kalawati Devi Harlalka v. CIT, 118 SC 100) in which we have just delivered judgment, and apart from the questions involved in that case, the only additional point raised before us in this appeal is that no fair and reasonable opportunity was given to the appellant, Rampyari Devi Saraogi, hereinafter referred to as the assessee, by the Commissioner of Income tax who passed the order dated March 15, 1963, under Section 33B of the Indian Income Tax Act, 1922. Following our judgment in Kalawati Devi Hartalka v. CIT we hold that the Commissioner of Income tax, West Bengal, Calcutta, had jurisdiction under- section 33-B of the Income Tax Act, 1922, to revise the assessment orders for the years 1952-53 to 1960-61.

2. To appreciate the additional point raised before us it is necessary to give the relevant facts. On March 8, 1963, the Commissioner of Income Tax, West Bengal, sent a notice under