SABYASACHI MUKHARJI, J.

( 1 ) THIS is an application challenging the assessment made under Section 144 of the Income-tax Act, 1961, for the assessment years 1967-68 and 1968-69. The assessee is National Hotel which runs a popular eating house in Calcutta known as Dilkusha Cabin. The assessee was represented by a receiver appointed by this court in Suit No. 890 of 1969. After the receiver took possession he found that no return had been filed for the assessment years 1967-68 and 1968-69. The receiver had received a notice under Section 139 (2) of the Income-tax Act, 1961. As he was unaware of the true position he applied for time to enable him to deal with the notice. The receiver, thereafter, found that no return had been filed nor any application had been made for extension of time to submit return. The receiver also did not file any application for extension of time to file return. These facts are not in dispute. Thereupon, the petitioner appeared on the 7th of October, 1971, before the respondent, Income-tax Officer, and the Income-tax Officer on the 15th of October, 1971, completed the assessments for the aforesaid two years under Section 144 of the Income-tax Act, 1961, to th

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