( 1 ) BY this petition under Articles 226 and 227 of the Constitution of India, the petitioner, a private limited investment company, impugnes the legality and validity of the notice dated 7th April, 1999 issued by the Commissioner of Income-tax, Delhi-1 V. respondent No. 2 herein, in exercise of the powers conferred on him by Section 263 of the Income-tax Act, 1961 (for short the Act) to show cause as to why the assessments made by the joint Commissioner of Income-tax (Assessments ). Special Range-VIII, on 24th February 1998 for the assessment years 1987-88,1989-90,1991-92,1992-93,1993-94 and 1994-95 be not set aside and suitable directions for re-doing the same as per law be not issued to the Assessing Officer as in his opinion the said assessment orders are erroneous insofar as they are prejudicial to the interests of the Revenue.

( 2 ) SHORN of unncessary details, the facts material for the purposes of this petition are: The petitioner deals in shares, stocks and securities. In its returns of income for the relevant assessment years the petitioner computed income on sale of certain shares under the head income from capital gains on the plea that these shares were no