The following question of law had been referred to the High Court for consideration under Section 66(1) of the Income Tax Act, 1922 by the Appellate Tribunal, Allahabad Bench, Allahabad: "Whether, on the facts and in the circumstances of the case, valid assessments could be made on 31st May, 1962, for the assessment years 1948 49 and 1949 50 on the basis of voluntary returns of income filed under Section 22(1) of the Indian Income Tax Act, 1922 on 18.11.1950? The matter came up before a Division Bench of the High Court and as there was a previous bench decision of that Court in the case of Sool Chand Ram Sewak vs Commissioner of Income tax, U.P. which supported the revenue 's case and as the division bench before whom this case came was unable to accept that view, the division bench referred the case to a larger Bench.