JUDGMENT

KRISHNA S.DIXIT, J. -

These two petitions having substantially similar factual matrix and involving identical questions of law, seek to lay a challenge to the orders dtd. 31/3/2022 passed u/s 148A(d) followed by evenly dated notices issued u/s 148 of the INCOME TAX ACT , 1961. The impugned action has been generated at the hands of 1st respondent.

I. FOUNDATIONAL FACTS OF THE CASES:

(a) Petitioner in W.P.No.8815/2022 is the husband of petitioner in companion W.P.No.8797/2022; they are an octogenarian couple. In the year 2010 and up to the year 2016, petitioner-Dr.Ramdas Madhava Pai acquired certain shares in Manipal Education and Medical Group India Private Limited (hereafter 'MEMGIPL'). In March 2017, his son Dr.Ranjan Pai gifted shares held in MEMGIPL to petitioner-Dr.Ramdas Madhava Pai. Likewise, his daughter-in-law gifted shares to petitioner-Smt.Vasanthi Pai. On 16/11/2017, the National Company Law Tribunal (hereafter 'NCLT') approved the scheme of demerger of the property management business of MEMGIPL into another company namely Manipal Integrated Services Private Limited (hereafter 'MISPL'). By way of consideration, 10, 87, 97, 101 shares of MISPL were allotted to