( 1 ) BY this application under Article 226 of the Constitution the petitioner, Nand Kishore Jhajharia, challenges the validity of certain reassessment proceedings for the assessment years 1946-47 to 1950-51 initiated by five several notices purported to be under Section 148 of the Income-tax Act, 1961. The original assessments for these years had been completed under Section 23 or under Sections 34/23 of the Indian Income-tax Act, 1922, before September, 1955, It also appears that for the assessment year 1949-50 a total income of Rs. 5,93,905 was determined under Section 23 (3 ). Thereafter, the petitioner filed a petition of disclosure and a settlement in writing was arrived at between the petitioner and the Commissioner of Income-tax, West Bengal, on 20th September, 1955, wherein, inter alia, the petitioner agreed to the determination of his total undisclosed income including the undisclosed income of his wife at Rs. 6,87,527. Out of this Rs. 2,00,502 was agreed to be spread over a period of six years, from the assessment year 1939-40 to the year 1944-45 and the balance of Rs. 4,87,025, to be distributed equally over a period of five years from 1945-46 to 1949-50.