Assessee became a Managing Director of a company after death of her husband. In course of investigation, Assessing Officer found that company had claimed a bogus payment of brokerage, a bogus payment of sub-agency commission and a bogus loss . Accordingly, Assistant Commissioner filed a complaint under Indian Penal Code (IPC) and under Income-tax Act treating assessee as Principal Officer of company. Petition to quash the complaint is filed before the High Court and the   Assessee contended that she was not in-charge and responsible for carrying on day-to-day affairs of company and that Assistant Commissioner ought to have issued a notice under S. 2(35) expressing his intention to treat assessee as Principal Officer of company and without such a notice, compliant filed against her was not maintainable. Dismissing the petition the Court held that , since assessee had subscribed her signature in profit and loss account and balance sheet for relevant assessment year which were filed along with returns, Assessing Officer was justified in naming her as principal officer and accordingly she could not be exonerated for offence under S. 277 of the Act. Court also held that  for filing a complaint under S.276(C)(1),  277 and  278B determination of a Principal Officer was not necessary and non-issuance of individual notice before filing of compliant would be of no consequence .( AY. 1985-86)