RAJAGOPALAN, J.

The petitioners, Veerappan Chettiar and Angidi Chettiar, along with two others, Ramaswami and Sundaram, constituted a firm with the vilasam Messrs. S. V. Veerappa Chettiar and Co. The firm was registered under section 26A of the Income-tax Act for the assessment years 1947-48, 1948-49 and 1949-50. The partnership was dissolved with effect from 13th April, 1951, and notice of the impending dissolution was given to the Income-tax Officer on 10th April, 1951.

For the three assessment years mentioned above the assessee was the registered firm. The assessment for 1947-48 was completed on 22nd March, 1950, that for 1948-49 on 28th September, 1950, and that for 1949-50 on 17th November, 1951. In the course of each of these assessment proceedings and before the assessment was completed, the Income-tax Officer issued notices to the assessee as required by section 28(3) of the Act, that it was proposed to take action to levy a penalty under section 28(1)(c). Those notices were dated 20th March, 1950, 27th September, 1950, and 15th November, 1951, respectively. The notices that related to 1947-48 and 1948-49 were thus issued before the dissolution of the firm, while