February, 1955 and the income was assessed at Rs. 36,068/-. Subsequently, while making assessment for the assessment year 1955-56~ the appellant was asked to furnish a wealth statement which was actually filed on the .30th June, 1954. From the wealth statement it was found that the appellant had made investments for Rs. 39,000/D during the previous year which ended on the 30th June, 1950, though in respect of that previous year, the appellant's income was assessed only at Rs. 36,068/-. A scrutiny of the wealth statement and the Bank account and the extensive nature of the business.catried on by the appellant led the Income-tax Officer to entertain a belief that the income of the year 1951-52 had been under-assessed. He E accordingly issued a notice under s. 34(1) and after examining the return made, he assessed the income of the appellant at Rs. 89,002/-· by his order dated the 31st March, 1960. The appellant filed an appeal against the assessment order to the Appellate Assistant Commissioner but the appeal was dismissed, the appellant preferred a further appeal to the Income-tax Appell'\te Tribunal, F Madras Bench. The appellant did not dispute the quantum of the assessment but only· the -jurisdiction of the Income-tax Officer to initiate proceedings under s. 34(1). The Tribunal by its order dated the 31st January, 1962 over-ruled the objection and dismissed lhe appeal. At the instance of the appellant, the Tribunal referred the following question of Jaw for the opinion of the High Court:
