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Income-tax Act (XI of 1922), S. 34(1)(a)-Escape of income -Re-assessment-Notice under S. 34(1)(a)-Period of 8 years, whether starts from accounting year or assessment year.   The period of 8 years prescribed by section 34(l)(a) of the Income-tax Act, 1922, for issuing a notice for re-assessment of income starts from the expiry of the assessment year and not from the expiry of the accounting year in relation to the income sought to be assessed.   Talluri Raghavaiah v. First Additional Income-tax Officer, Bapatla (1962) 44 I T R 136 fol.   Pannalal Nandlal Bhandari v. Commissioner of Income-tax (1961) 41 I T R 76 explained.   STATEMENT OF CASE   By this application, Gowra Venkayya Chetty, the assessee, requires the Appellate Tribunal to refer to the High Court some questions, said to be of law and which are said to arise out of its order, under section 33(4) made on April 5, 1959, in I. T. A. No. 9228 of 1957-58. Inasmuch as, in our opinion, a question of law does arise out of the aforesaid order, we hereby draw up an agreed statement of the case and refer it to the High Court of Judicature of Andhra Pradesh at Hyderabad under section 66 (1) of the Indian Income-tax Act, 1922.   2. This reference arises out of a re-assessment made upon the assessee for the assessment year 1948-49 after taking recourse to the provisions of section 34. The relevant account year for the said assessment year is the financial year, April 1, 1947, to March 31, 1948. The questions required to be referred to the High Court are as follows;   "(1) Whether on the facts and circumstances of the case the assessment under section 34(1)(a) is legal ?   (2) Whether on the facts and circumstances of the case the notice issued under section 34(1)(a) after a period of eight years from the account year is valid ?"   When the application came up for hearing before us we were told that by both these questions the assessee-applicant merely wanted to challenge the validity of the reassessment on a single ground to be presently mentioned, and none was directed against the quantum of the assessment as such. Hence the material facts, having bearing on…