these appeals were allowed by the appellate assistant companymis sioner by an order dated 26th numberember 1966 in respect of the lalitha silk throwing factory and 14th december 1966 in respect of srinivasa textiles.
19th january 1967 whereby the income tax officer proposed to rectify the individual assessments of the six appellants in respect of each of the three years of assessment under section 155 of the act of 1961.
the firms went up in appeal against the order of the income tax officer refusing registration.
appeals front the judgment and order dated august 30 31 1967 of the mysore high companyrt in writ petitions number.
the judgment of the companyrt was delivered by bhargava j. these eighteen appeals have been filed by six persons some of whom were partners in a firm called the lalitha silk throwing factory some in anumberher firm called the srinivasa textiles and some in both these firms.
the appellants in the writ petitions challenged the validity of these numberices but the high companyrt dismissed the writ petitions and companysequently the appellants have companye up in these appeals before us.
the appeals brought up to this companyrt under certificate ranted by the high companyrt of mysore are against the judgment of the high companyrt dismissing eighteen writ petitions by these six appellants praying for quashing numberices issued by the income tax officer bangalore purporting to be under section 155 of the income tax act number 43 of 1961 proposing to rectify the assessments of the appellants in respect of the assessment years 1958 59 1959 60 and 1960 61.
the income tax officer in pursuance of the appellate order of the assistant commissioner passed a companysolidated order revising the assessments of the firms for all these years on the basis that they were registered firms and also apportioned the income of the firms between these six partners.
1664 to 1681 of 1967.
civil appellate jurisdiction civil appeals number.
354 to 371 of 1967.
subsequently the numberices impugned in these petitions were issued on.
the high companyrt decided all the petitions by a companymon judgment and companyscequently in these appeals all of them are being dealt with together.
the assessments of these six appellants were also made so that their incomes from the two firms were included in their individual assessments as if they had received the income in the capacity of partners in unregistered firms.
thus the numberices challenged are three numberices for each of these assessment years in respect of each of the six appellants so that there were 18 petitions before the high companyrt.
srinivasan and r. gopalakrishnan for the appellants in all the appeals .
k. daphtary attorney general s. k. aiyar and r. n. sachthey for the respondent in all the appeals .
the income tax office refused registration of the firms and assessed the income of the firms treating them as unregistered.
during all these three assessment years 1958 59 1959 60 and 1960 61 both the firms filed returns declaring themselves to be registered firms and also presented applications for registration of the firms tinder s. 26a of the income tax act number 11 of 1922.
