CHAKRAVARTTI, C. J.

( 1 ) THIS appeal involves a short and simple point, but it was sought to be presented as if it involved an intricate question of interpretation of statutes and also a profound question of constitutional law. In my opinion, whatever the true answer to the question may be, there is no room for either intricacy or profoundity.

( 2 ) THE facts are equally simple. The respondent is a private limited company, incorporated under the Indian Companies Act and having its registered office at 8, Clive Row, Calcutta. For the assessment years 1942-43, 1943-44 and 1944-45, assessments were made on it by three several orders, dated respectively 26-1-1944, 12-2-1944 and 15-2-1945. Those assessments were made under Section 23 (3), Income-tax Act, upon returns being furnished and the amounts of tax demanded were duly paid. Subsequently, on 28-3-1951, three separate notices were issued to the respondent, calling upon it to submit fresh returns for the three accounting years, relative to the said three assessment years, with a view to re-assessments of the income. Those notices were issued under SECTION 34, Income-tax Act, as amended by the Income-tax and Business Profits Tax (A

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