Judgment

D.P. Wadhwa, J.-These appeals are from the judgment dated December 18, 1984 of Division Bench of the Delhi High Court dismissing writ petitions of the appellant for various assessment years. In these writ petitions, the appellant had challenged notices issued under Section 148 of the Income Tax Act, 1961 (for short, the ‘Act’). Civil Appeal 4074/85 pertains to assessment year 1969-70 and CAs 4075/85 and 4076/85 to assessment year 1967-68 and 1968-69 respectively. Civil Appeal 1089/85 pertains to 3 assessment years-1971-72, 1972-73 and 1973-74. For the assessment year 1970-71, there are two appeals and these are CAs 1090/95 and 1091/85. While for each assessment year there was separate writ petition in the High Court, for assessment year 1970-71, there were two. Reason for two writ petitions for the assessment year 1970-71 was that while the first writ petition chal­lenged the notice under Section 148 of the Act, second was filed as by that time the Income Tax Officer had completed the assessment and, thus, there was a challenge to the assessment itself.

2. The appellant is a wholly owned subsidiary of the Coca-Cola Company which is a company incorporated under the laws of th