( 1 ) SINCE a common question of law is involved, both the cases are being disposed of by this judgment.

( 2 ) THE intimation letters sent to the petitioners, hereinafter REFERRED TO to as the assessee, under Section 143 (1) (a) of the Income-tax Act, 1961 (for short the Act ), after making certain adjustments to the total income returned by them and demanding additional tax under Section 143 (1a) of the Act, are under challenge in these writ petitions.

( 3 ) IN order to appreciate the issue involved and the rival contentions, we shall briefly refer to the facts of each of the cases.

( 4 ) IN CWP 2087/91, the assessee, engaged in the business of manufacture, sale and export of colour picture tubes, filed its return of income for the previous year ending 31 March 1990, relevant to the assessment year 1990-91, on 28 December 1990, declaring a loss of Rs. 21,16,08,308/ -. The return was accompanied by tax audit report, audited balance sheet, profit and loss account and some other documents. while arriving at the said loss the assessee suo motu offered certain expenses for disallowance in accordance with the provisions of the Act. However, out of the expenses booked under va