(1.) These two petitions are filed by the same petitioner under Art. 226 of the Constitution and call in question two separate but similar orders of the common respondent the Income-tax Officer, Quilon. The question is whether the Income-tax Authority acted in excess of jurisdiction when he purported by these orders to rectify, on ground of alleged mistake, two original orders already passed, assessing the petitioner to income-tax for the consecutive years 1124 M. E. and 1951-52. We will take up these petitions in their order.
(2.) O. P. No. 119 of 1955. The petitioner is a merchant in Quilon. He carries on two lines of business activity, one being in tobacco, wholesale and retail, and the other in cashew kernels, manufacture and export.
(3.) His assessment to income-tax for the year 1124 was made by order dated 30-5-1953 under the Travencore Income-tax Act, 1121. This order is filed as Ext. A and it shows that his total income was made up under three heads as follows : <FRM>JUDGEMENT_885_ITR28_1955_1.html</FRM>