SABYASACIII MUKHARJI, J.

( 1 ) THE subject-matter of challenge in this application under Article 226 of the Constitution is the notice dated 9th July, 1973, issued under Section 154/155 of the I. T. Act, 1961, In order to appreciate the question involved in this application it would be necessary to refer to certain facts. The petitioner is a public limited company. The petitioner is engaged in the business of manufacture and sale of aluminium utensils and articles. One of the main businesses of the petitioner, according to the petitioner, consisted of export of aluminium utensils and articles and goods outside India. The petitioner is an exporter of aluminium goods and articles to countries outside India. By export of the said aluminium articles and goods the petitioner earned what is known as import entitlement. The petitioner sold the said import entitlement. I am concerned in this application under Article 226 of the Constitution with the question relating to the assessment year 1965-66. On the 18th March, 1970, the ITO made an assessment for the said year. In the assessment the petitioner had contended that the amounts realised by the petitioner from the sale of import entitle

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