( 1 ) THE assessment year involved in this application is 1963-64. The assessment for the aforesaid year was completed on 30th March, 1972 (? ). By a notice dated 30th March, 1972, the said assessment is sought to be reopened under Section 148 of the Income-tax Act, 1961. The said attempt is under challenge in this application under Article 226 of the Constitution.

( 2 ) THE petitioner which is a partnership firm states that the firm received a letter dated 21st June, 1971, on the 28th June, 1971, from the Income-tax Officer, "j" Ward, Dist. IV (I), Calcutta, whereby the petitioner was informed that there was information in the possession of the said Income-tax Officer on the basis of which the Income-tax Officer held that M/s. Atlas Agencies of 51/59, Dariastan Street, Bombay-3, was a concern of the petitioner. Accordingly, the Income-tax Officer wrote that the income of that concern should have been assessed in the hands of the petitioner. The petitioner was, therefore, asked to show cause why action should not be taken against him to reassess the alleged income of the petitioner for the assessment years 1963-1964, 1964-65 and 1965-66 for including the a