Bias in tax notices and consolidated assessment of common exemption issues were examined, with no mala fides found.

Income-tax notices were not shown to be vitiated by bias or mala fides, because the record disclosed no material suggesting improper motive and the later notices were issued after an earlier assessment had been set aside, with intervening assessment years and expiring return-filing time. The challenge on that ground therefore failed. Where the exemption issue was common to multiple assessment years, the Court considered it proper in the interests of justice to take all years together, and indicated that the related wealth-tax proceedings could also be heard simultaneously. The writ petition was dismissed on merits, subject to those observations on consolidated consideration of the tax matters.

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Issues: (i) whether the income-tax notices were liable to be interfered with on the ground of bias or mala fides; (ii) whether the assessment proceedings for different years and the wealth-tax proceedings should be taken up together because the question of exemption was common to all years.

Issue (i): whether the income-tax notices were liable to be interfered with on the ground of bias or mala fides.

Analysis: The Court found no material to show that the Income-tax Officer was biased or actuated by mala fide considerations. The earlier assessment had been set aside and remanded for fresh decision, and the subsequent notices were issued because later assessment years intervened and the time for filing returns was running out.

Conclusion: The challenge based on bias or mala fides failed and no interference was warranted.

Issue (ii): whether the assessment proceedings for different years and the wealth-tax proceedings should be taken up together because the question of exemption was common to all years.

Analysis: Since the central controversy whether the petitioner was exempt from income-tax was common to all the assessment years, the Court found it proper in the interests of justice that all the years be taken up together. The Court also indicated that proceedings under the Wealth-tax Act could be taken up simultaneously.

Conclusion: The Court directed that the matters be considered together for all years, including the wealth-tax proceedings.

Final Conclusion: The writ petition was not allowed on merits and stood dismissed, though the Court made observations for consolidated consideration of the petitioner's tax matters.

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