These are three appeals from three judgments of the High Court of Judicature at Patna. The appellants are all residents of Jhumritalaiya, a place in the district of Hazaribagh in Chotanagpur Division of Bihar. By an Order in Council, dated 3rd March, 1936, Chotanagpur and Santal Parganas were declared to be “partially excluded areas”. The questions involved in these appeals are with regard to the assessment of the appellants to income-tax for the year 1940-41. Except for minor differences in the dates, the points of law raised in the appeals and the facts are identical. Under the circumstances one judgment can conveniently dispose of the three appeals.

The assessees have been assessed for the year 1940-41. Their accounting year was 1939-40. On or about the 20th April, 1940, a notice under section 22 (2) of the Income-tax Act was served upon the assessees requiring them to furnish a return in the prescribed form. On the 22nd April, 1940, a notice under section 22 (1) of the Income-tax Act was published in the newspapers requiring persons generally to submit the returns in the prescribed form. The Indian Finance Act of 1940 had not been extended by any Notification up to tha