P.R. Bora, J.

1. Rule. Rule is made returnable forthwith with the consent of the learned counsel for the parties.

2. Validity of a notice under Section 148 of the Income Tax Act, 1961 served on the petitioner company, whereby reassessment has been ordered is challenged by it in these two writ petitions. Notice in Writ Petition No.2005/2013 relates to reassessment for A.Y. 2006 – 2007 whereas notice in Writ Petition No. 6606/2013 pertains to the reassessment for A.Y. 2008 – 2009. Since grounds of challenge in both the writ petitions are same, they are being decided by this common Judgment.

3. Petitioner is a private limited company duly registered under the provisions of the Companies Act, 1956. It is a regular assessee under the Income Tax Act, 1961 (for short “the Act”). The petitioner company is the authorized dealer for spare parts of Kirloskar Pumps and does exclusive supply to mines of Western Coalfields Limited and South Eastern Coalfields Limited.

4. Petitioner company had filed income tax return for the assessment year 2010 – 2011 under Section 139(D) of the Act showing taxable income Rs.80,54,340/- for the said year. The said return was processed under Section 143