( 1 ) IN this application under Article 226 of the Constitution of India (the writ petition in short), the writ petitioner questioned three notices issued under Section 148 of the IT Act, 1961 (the said Act in short), dt. 26th Sept. , 1996, for the asst. yrs. 1989-90 and 1990-91 and dt. 20th Sept. , 1996, for the asst. yr. 1991-92.

( 2 ) THE relevant facts for the disposal of the writ petition are summarised as under: (a) The petitioner, a public limited company, is engaged in businesses of travel agency and tour operation. The petitioner is an agent of the airlines for selling air tickets and for rendering such services, it receives commission from such airlines. Similarly, the petitioner acts as an agent for various hotels and it gets commission from such hotels for booking accommodations on behalf of the clients of the petitioner. Apart from the aforesaid businesses of acting as the agent of airlines and of hotels, the writ petitioner, also carries on business of tour operation. The writ petitioner, however, receives only the amount of commission, which the writ petitioner is entitled to receive from the said airlines and the hotels for rendering its