Thereafter, in the year 1961, the Agricultural Income tax Officer asked the assessee to submit its return for the assessment years 1955 56 to 1961 62.
In response to that demand the assessees submitted their return for the assessment year 1955 56 on March 5, 1962.
It appears that in February, 1962, the Income tax Officer again called upon the assessee to submit their returns for the assessment years in question.
Their companytention was number upheld either by the Income tax Officer or by the appellate authority.
Thereafter, the assessees challenged the impugned order of assessment before the High Court of Assam and Nagaland, but the High Court dismissed their petition.
The Income tax Officer assessed the income of the assessees on the basis of the said return.
The assessees challenged the validity of that assessment on the ground that the same was barred by limitation.
Against the decision of the High Court, this appeal has been brought by special leave.
The appellants in the cases are the owners of a tea estate.
But, the assessees did number submit any return.
