SABYASACHI MUKHARJI, J.

( 1 ) ON the 29th March, 1967, a notice was issued to the petitioner I. C. I. (India) Private Ltd. by the Gift-tax Officer, 'b' Ward, Companies Dist. IV, Calcutta, intimating that he had reason to believe that the gift made by the petitioner assessable to gift-tax for the assessment year 1962-63 had escaped assessment. The assessee was, therefore, required to file a return of the gift made by the assessee for the aforesaid assessment period. The petitioner replied on the 15th May, 1967, intimating to the Gift-tax Officer that it was unaware of any gift having escaped assessment to gift-tax and accordingly it submitted a nil return in the prescribed form. It is the validity of the said notice, which was issued under Section 16 (1), of the Gift-tax Act, 1958, which is under challenge in this application under Article 226 of the Constitution. In order to appreciate this challenge it is necessary to refer to certain facts. The petitioner is a subsidiary of the Imperial Chemical Industries Ltd. incorporated in the United Kingdom. The said Imperial Chemical Industries Ltd. is shortly referred to as ICI. It is the case of the petitioner that after the last world w

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