RAJAGOPALA IYENGAR
Sree Rajendra Mills Limited and Others – Appellant
Versus
Income Tax Officer, Central Circle 1, Madras – Respondent
RAJAGOPALA AYYANGAR, J.
These four petitions are directed to challenge the validity of a notice issued to the respective petitioners under section 34(1A) of the Indian Income-tax Act. This section was introduced by the Amending Act XXXIII of 1954, and one of the points raised in these petitions is as regards the constitutional validity of this amending provision.
We shall state a few preliminary facts before dealing with the contentions urged by the learned counsel for the petitioners. Rajendra Mills Ltd., Salem, are the petitioners in W.P. No. 307 of 1955, the Meenakshi Mills Ltd., at Madurai are the petitioners in W. P. No. 308 of 1955 while W. P. No. 309 of 1955 is by the Saroja Mills Ltd., Coimbatore, and these three mills are managed by Sri Karumuttu Thiagarajan Chettiar, who has a controlling interest in each of these three companies; and Sri Thyagarajan Chettiar as an individual is the petitioner in W.P. No. 310 of 1955. For the assessment years 1940-41 to 1946-47 the several petitioners were assessed to income-tax and they have been making payments towards the taxes as assessed, and appeals filed in regard to some of these assessments are pending before various Tr
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