(1.) THIS petition turns on the application of Section 53 of the Finance Act, 1964, to the expenditure incurred by the deceased, Shanmugha Raja, between July 1, 1962, and March 11, 1963. After his death on March 11, 1963, the Expenditure-tax Officer, Karaikudi, by a notice under Section 13(2) of the Expenditure-tax Act, 1957, which was dated August 18, 1964, called upon his widow to furnish a return of the expenditure incurred by him for the expenditure-tax assessment year 1964-65. By a later correspondence from the department it appears that the requisition for return was confined to the year ended June 30, 1963.
(2.) THIS shows, and it is not in dispute, that the deceased Raja of Sivaganga followed the year from July 1 of a year to June 30 of the following year.