Jagannatha Shetty, J.—In this batch of writ petitions under article 226 of the Constitution, the petitioners challenge the validity of the orders made by the Commissioner of Income Tax under section 263 of the Income Tax Act, 1961, for short "the Act".

2. The facts in all these cases are similar and, for the sake of convenience, I set out those leading up to the petition in W.P. No. 6660 of 1974. The petitioner herein is a lady. She filed voluntary returns of income for the assessment that it was her previous savings inclusive of the gifts given to her at the time of her marriage. She was not assessed to tax previously. Along with the returns of income she filed a letter dated October 20, 1972, which reads as follows :

"With reference to the above, I beg to request you that out of my previous savings I am now having cash of Rs. 31,500 with me and that I may be assessed as under :

 Y.E.

Asst. Year :

Rs.

21-10-68

69-70

7,500

9-11-69

70-71

7,800

30-10-70

71-72

8,000

19-10-71

72-73

8,200

31,500

and have enclosed Form No. 3 for all the above 4 years. I have not been assessed to Income Tax anywhere in India and have submitted the above 4 returns voluntarily."

On October 25, 1972, she submitted anot