Judgment :- VEERASWAMI J. 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. This show, 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. The present petition under article 226 of the Constitution is to forbid the Expenditure-tax Officer from proceeding further. The ground of the petitioner is that, on a proper interpretation of section 53 of the Finance Act, 1964, there was no liability to return at all as the petitioner had been called upon to do. The section uses the phraseology "for every financial year commencing on or after the first day of April, 1964" * . Mr. Vedantachari, for the petitioner, contends that having regard to this language, charge to expenditure-tax would arise only in respect of expenditure incurred subsequent to April 1, 1964. In any case, he would say that, since the petitioner's husband had died on March 11, 1963, the respondent was not justified in calling for the return. This argument is addressed on the assumption that section 53 of the Finance Act, 1964 The petition is dismissed with costs. Counsel's fee Rs. 250.