( 1 ) IN these two writ applications the petitioner, Messrs. Grindlays Bank Ltd. challenged certain notices issued under Section 148 of the I. T. Act, 1961 (hereinafter referred to as "the Act" ). In Civil Rule No. 15774 (w) of 1975, the petitioner has challenged notices under Section 148 of the Act in respect of the assessment years 1958-59, 1966-67, 1967-68, 1968-69, 1969-70 and 1970-71.

( 2 ) IN Civil Rule No. 8747 (w) of 1976, the petitioner has challenged notices under Section 148 of the Act in respect of the assessment years 1959-60, 1960-61, 1961-62, 1962-63, 1963-64, 1964-65 and 1965-66.

( 3 ) AS almost identical questions of fact and law arise in both these civil rules by consent of parties, the two rules were heard together and one set of arguments were advanced in both.

( 4 ) ALTHOUGH the reasons recorded by the ITO justifying the reopening of the assessment for the above-mentioned years were not set out either in the affidavit-in-opposition filed on behalf of the revenue or in any of the annexures thereto, they were produced before me from the records at the time of the hearing. By consent of parties, copies of all the recorded reasons for the a