( 1 ) THE short point involved in this appeal is whether reasonable opportunity or being heard was given to the respondent by the appellant No. 1. , who issued a notice in writing in connection with a proceeding under Section 33-B of the Income Tax Act, 1922, (hereinafter referred to as the Act ). One of the notices issued by the appellant No. 1, in the circumstances hereinafter stated, was received by the respondent at Bldasar, District Churu, Rajasthan, on May 8, 1963. By this notice the respondent was informed that the date of hearing was fixed for May 9, 1963.

( 2 ) THE respondent, having her residence at Basirhat in the district of 24-Parganas, used to be assessed to income tax by the Income Tax Officer, B-Ward, Dist. 24 Parganas. The appellant No. 1 served a notice on the respondent informing her that on examination of the assessment records for the years 1953-54 to 1961-62 and other connected records, he considered that the orders of assessment passed by the said Income Tax Officer on June 14, 1961, were erroneous as they were prejudicial to the interest of revenue. In this notice various grounds for reopening the assessment orders for the above mentioned a