( 1 ) IN this case we are concerned with the Income-tax assessment of the petitioner Sheo Nath Singh for the years 1941-42 to 1946-47. The petitioner, according to his own petition, has at all material times been a shareholder of a number of companies engaged in the business of managing hotels and as a result of such shareholding, he became director and managing director of various companies. At one time he became the owner of a large block of shares of Spence's Hotel Ltd. and was formerly an ex-managing director, and is now incharge of the management thereof. According to the petitioner, in the year 1945-46 Rai Bahadur Oberoi purchased from him his share-holding in the Associated Hotels of India Ltd. (hereinafter referred to as the "associated Hotels") for a sum of Rs. 20,65,705-13-0 pies. Similarly, in 1949 another block of shares was purchased by the said Rai Bahadur Oberoi in the said company. It appears that the case of Rai Bahadur Oberoi was referred to the Income-Tax Investigation Commission, set up under the provisions of the Taxation on Income (Investigation Commission) Act, 1947. The said Commission, on or about 18th August, 1951 issued notices under Section