SABYASACHI MUKHARJI, J.

( 1 ) FOR the assessment year 1956-57 the petitioner was assessed on the 25th August, 1960, under Section 23 (3) of the Indian Income-tax Act, 1922. This assessment was made pursuant to a voluntary return filed by the petitioner. In the said return it was the case of the petitioner that the petitioner had sold his wife's ornaments, received at the time of her marriage, at Rs. 1,03,000 in October, 1955, and March, 1956. Upon that basis the assessment was made. Thereafter, on the 25th May, 1967, a notice was received by the petitioner which is the subject-matter of challenge in this application. By the said notice the petitioner was asked by the Income-tax Officer, E-Ward, District I, Calcutta, to give the particulars of the persons to whom gold ornaments were sold. The petitioner was further asked to show cause why the income-tax assessment for the assessment year 1956-57 should not be reopened under Section 147 (a) of the Income-tax Act, 1961, and the petitioner was also required to comply with the said notice by the 31st May, 1967. The petitioner was requested to produce evidence in support of the above statement made in the original return. Subsequent to

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