Judgment

KHANNA, J.:- This appeal on certificate is against the judgment of Gujarat High Court dismissing petition under Art. 226 of the Constitution of India filed by the appellant for a writ of certiorari or other appropriate writ to quash two notices issued by the respondent to the appellant under Section 148 of the Income-tax Act, 1961 (hereinafter referred to as the Act of 1961).

2. The matter relates to the assessment years 1957-58 and 1959-60. The appellant is a public limited Company which carries on the business of manufacture of pottery and sanitary wares at Morvi and other places in the State of Gujarat. In respect of the assessment year 1957-58, the corresponding accounting year for which ended on July 31, 1966, the appellant filed its return under the Indian Income-tax Act, 1922 (hereinafter referred to as the Act of 1922). The predecessor-in-interest of the respondent by assessment order dated April 16, 1959 assessed the total income of the appellant at Rs. 4,60,372. In computing the said income the Income-tax Officer allowed depreciations amounting to Rs. 5,05,487. For the assessment year 1959-60 the appellant likewise filed return. Assessment order in respect of that