( 1 ) BURMAH-SHELL Oil Storage and Distributing Company of India Ltd. (hereinafter referred to as the company or the petitioner) has presented this writ petition challenging the validity of two notices one bearing No. CC-XXIII/5-b/67-68/79, dated the 17th August, 1971, issued by the Income-tax Officer, Central Circle XXIII, Calcutta, and the other bearing No. 1426/iac/icfp-124/67-68, dated the 18th August, 1971, issued by the Inspecting Assistant Commissioner of Income-tax, Range-1 (C), Calcutta.

( 2 ) THE petitioner is a company incorporated under the provisions of the English Companies Acts with liability of its members limited by shares and has its registered office at Burmah House, Piper Sway, Swindon, in the United Kingdom. The petitioner carries on business, inter alia, at Burmah Shell House, Ballard St. , Bombay-1, and also at No. 31, Binoy Badal Dinesh Bag, in the town of Calcutta. The business of the company consists in the importation and of purchase and storage, sale and distribution of petroleum and allied products. The capital of the company has been contributed in pounds sterling and as on 31st December, 1966, the authorised capital of the company cons