SABYASACHI MUKHARJI, J.

( 1 ) THIS is an application under Article 226 of the Constitution challenging the rectification proceedings under Section 154 of the Income-tax Act, 1961. For the assessment year 1963-64, the petitioner filed its return of income along with and supported by its audited profit and loss account, balance-sheet, depreciation statement and various other statements. The petitioner is a company and carries on business of manufacture and sale of safety razor blades, steel files, bandsaws, small tools and other articles. The petitioner alleges that during the course of the said assessment proceedings for the said assessment year before the Income-tax Officer the petitioner produced and/or caused to be produced various books of accounts, papers and other documents and had given various explanations, information and evidence that was necessary and/or required by the Income-tax Officer. The petitioner contends that the petitioner disclosed all primary facts and material facts necessary for the proper assessment. Since the assessment year 1952-53 onwards including the assessment year 1963-64 the petitioner had claimed and had been allowed depreciation at the special ra

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