ORDER :

1. These appeals are preferred against the judgment of the Andhra Pradesh High Court answering the following question in the affirmative that is in favour of the Revenue and against the assessee :

Whether, on the facts and in the circumstances of the case, the assessments for the years 1960-61, 1961-62 and 1962-63 have been validly reopened under Section 147(b) of the Income-tax Act, 1961 ?

2. The appellant is the Andhra Bank Limited and the assessment years concerned are 1960-61 to 1962-63. The bank was following the calendar year as its accounting year. In the course of its banking business, it was purchasing Government securities and also selling them from time to time. On Government promissory notes and securities, interest is payable on specified dates, but, all the same, the transferor or the transferee can calculate the interest which has accrued on such promissory notes and pay or receive such amount of interest on the date of and up to the date of purchase or sale. The assessee was also adopting this method and it was being accepted by the income-tax authorities until the assessment year 1958-59. However, with effect from the assessment year 1959-60, the assessee ch