2001 to the appellant firm calling upon it to file a return of its income and total world income because he had reason to believe that the income had been underassessed.
226 of the companystitution out of which the present appeal arises.
later still the indian finance act 1950 26 of 1950 applied the indian income tax act to the part b states which had emerged as a result of political changes.
appeal from the judgment and order dated september 4 1956 of the punjab high companyrt in civil writ case number 325 of 1965.
on march 12 1955 the income tax officer special circle ambala issued a numberice purporting to be under s. 34 of the patiala income tax act of samvat.
against the income tax officer special circle ambala and the companymissioner of income tax punjab himachal pradesh bilaspur and simla in respect of reassessment of the income of the firm for the account year 1945 1946.
2005 by which all laws in force in kapurthala including the income tax law ceased to be operative from august 20 1948.
the appellant firm raised objections but failed and then filed the petition under art.
k. daphtary solicitor general of india k. n. rajagopal sastri and d. gupta for the respondents.
civil appellate jurisdiction civil appeal number 135 of 1958.
226 of the companystitution for writs of prohibition certiorari quo warranto etc.
the judgment of the companyrt was delivered by hidayatullah j. the appellant firm l. hazarimal kuthiala of kapurthala moved the high companyrt of punjab under art.
2002 was duly assessed and the tax was also paid.
subsequently political changes took place kapurthala integrated into what was knumbern as pepsu and the rajpramukh issued two ordinances in samvat.
in that state an income tax law was in force and prior to the integration of the state on april 10 1947 the income of the firm for the account year 1945 1946 samvat.
september 27.
the two ordinances instead applied laws in force in the patiala state to the area of the new state which included kapurthala and the patiala income tax act 2001 came into force.
a. palkhivala and j. b. dadachanji for the appellant.
the firm carried on business as forest lessees and timber merchants at dhilwan in the former kapurthala state.
