( 1 ) BECAUSE common questions of law and facts arisa in these six petitions the are disposed of by this common order.

( 2 ) THE petitioner in WPs. 3447, 3448 and 3578 of 1973 is M/s Stump schuela and Somappa (P) Ltd In WPs. 3447 and 3448 of 1973 the petitioner has questioned the notices issued by the Income Tax Officer under s. 8 of the Companies (Profits) Surtax Act, 1964 (hereinafter referred to as the Act), in respect of assessment years 1969-70 and 1970-71. In WP. 3578 of 1973 the petitioner has questioned th? validity of the notice issued under S. 16 of the Act by the) Commr of Income Tax in respect of assessment year 1971-72. WP. 1131 of 1974 is filed by Senapathy Whitely (P) Ltd, questioning the validity of the notice issued by the Commr of I. T. under s. 16 of the Act in respect of assessment year 1969-70. WPs2551 and 2552 of 1974 are filed by International Instruments P Ltd questioning the validity of the notices issued by the ITO under S. 8 of the Act in respect of the assessment years 1970-71 and 1971-72.

( 3 ) THE petitioners are assessees under the Act. The assessments during the relevant years were completed under the Act by the Income tax Authorities and the amounts

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