( 1 ) THE petitioners in the above petitions ape all registered firms who are assessed to income-tax under the provisions of the Income Tax Act 1961 hereinafter referred to as the Act. Because a common ouestion of law arises for consideration in all these petitions they are disposed of by this common judgment.

( 2 ) WPS. 926 927 and 928 of 1972 are fied by M|s. M. Nagappa and the relevant assessment years are 1965-66 1966-67 and 1968-69. WP. 3401/73 is filed by M/s. Southern Express Transport Co. , and the relevant year of assessment is 1969-70. WPs. 3402 and 3403|73 are filed by M/s. Mahadeswara lorry Service against the orders of assessment passed in respect of assessment years 1969-70 and 1970-71. Being aggrieved by the amount of interest claimed under S. 139 of the Act and included in the relevant orders of assessment the petitioners have filed those petitions. The concerned Income tax Officer the Union of India and the Commr of Income Tax have been impleaded as respondents. In all the cases interest under S. 139 is calculated at the prevailing rate on the amount of tax which would have been payable if the concerned firm had been assessed as an unregistered firm. The contention

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