COMMON ORDER: (Ramesh Ranganathan, J.) W.P. No.18256 of 2008 is filed seeking a direction to quash the show cause notice, issued by the respondent on 02.02.2007, as without jurisdiction. The petitioner seeks a further direction for refund, with interest, of Rs.1,73,76,124/- and return of all the documents seized by the respondent as stated in the panchanama. W.P. No.20446 of 2008 is filed seeking a direction to quash the show cause notice, issued by the respondent on 07.02.2007, as without jurisdiction. The petitioner seeks a further direction for refund, with interest, of Rs.25,40,591/- and return of all the documents seized by the respondent as referred to in the panchanama dated 27.10.2005. As the questions raised, in challenge to the impugned orders, are common in both the writ petitions they were heard together and are now being disposed of by this common order.

2. Both Sri K.V. Satyanarayana, learned Counsel for the petitioner and Sri A. Rajasekhar Reddy, learned Assistant Solicitor General would submit that the facts in W.P. No.18256 of 2008 are representative of both the writ petitions and it would suffice for their disposal to note, in brief, the facts stated t