PINAKI GHANDRA GHOSE, J.

( 1 ) THE petitioner has challenged a notice dated May 24, 1993, issued by the Income-tax Officer, respondent No. 1 herein, under Section 148 of the Income-tax Act, 1961 (hereinafter referred to as "the said Act"), and the reassessment proceedings under Section 147 of the said Act for the assessment year 1989-90 and all proceedings relating thereto and thereunder on the ground that the conditions precedent for the assumption of jurisdiction have not been satisfied and as such notice and assessment proceedings are wholly without jurisdiction.

( 2 ) THE facts of the case briefly are as follows : the writ petitioner is the sole executor to the estate of Sundar Devi Rampuria who died on October 28, 1975, leaving a registered will dated May 6, 1964 (hereinafter referred to as "the said deceased" ). A probate of the said will has been granted to the petitioner. According to the petitioner, apart from the status of the said executor to the estate of the said deceased, the petitioner is also regularly assessed separately with his own income in the status of an "individual".

( 3 ) THE petitioner duly filed a return for the assessment year 1989-90 as sole executor

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