JUDGMENT

KULDIP SINGH, J.:- The appellantcompany carries on the business of exporting manganese ore to England and United States of America. The Income-tax Officer, Nagpur issued a notice dated Marjh 20, 1970 under S. 148 of the Income-tax Act, 1961 (hereinafter called the Act) stating that he had reasons to believe that the income of the appellant chargeable to tax for the assessment year 1953-54 had escaped assessment within the meaning of S. 147 of the Act. The company was called upon to show cause why it should not be reassessed to income for the said year. The appellant-company challenged the notice by way of writ petition under Art. 226/227 of the Constitution of India before the Nagpur Bench of the RP may High Court. The High Court by its judgement entdated August 5, 1975 dismissed the writ petition with costs. This appeal via special leave petition is against the said judgment of the High Court.

2. The relevant facts are hereinafter. The appellant is a non-resident company having its office in London. It has its office in India at Nagpur. The appellant is assessed to incometax at Nagpur and it has been the practice of the appellant-company to produce before the Income-tax Off