( 1 ) THIS is an application under article 226 of the Constitution challenging the validity of certain notices issued under Section 148 of the Income-tax Act, 1961 (hereinafter referred to as "the Act"), and Served on the petitioner by the respondent-Income-tax Officer with the object of reopening the petitioner's assessments for the years 1959-60, 1960-61 and 1961-62, on the ground of the petitioner's failure to disclose fully and truly all material facts for the purpose of its assessments for these years.

( 2 ) SECTION 147 of the Act is more or less identical in terms with Section 34 (1) of the repealed Income-tax Act, 1922, and provides as follows :" If- (a) the Income-tax Officer has reason to believe that, by reason of the omission or failure on the part of an assessee to make a return under Section 139 for any assessment year to the Income-tax Officer, or to disclose fully and truly all material facts necessary for his assessment for that year, income chargeable to tax has escaped assessment for that year, or (b) notwithstanding that there has been no omission or failure as mentioned in Clause (a) on the part of the assessee, the Income-tax Officer has in cons