Vibhu Bakhru, J.

1. These two writ petitions are filed by Bharat Sanchar Nigam Limited (BSNL) and seek to challenge the notices under Section 148 of the Income Tax Act (hereinafter also referred to as “the Act") and the proceedings initiated pursuant thereto, for reopening the concluded assessments for the assessment year 2001-02 and 2002-03. The petitioner has, in Writ Petition No. 550/2007 challenged the notice dated 23.11.2005 issued under Section 148 of the Act and the order dated 08.02.2006 passed by the Assessing Officer rejecting the objections raised by the petitioner against the reasons for issuance of the notice dated 23.11.2005. The Assessing officer had, by the notice dated 23.11.2005, initiated proceedings for reassessment of income for the period relevant to the assessment year 2001-02. The challenge in the Writ Petition No. 7707 of 2007 is with respect to the notice dated 12.3.2007 issued under Section 148 of the Act for initiating re-assessment proceedings in relation to the Assessment year 2002-03. As both the writ petitions raised similar issues, the same were taken up for hearing together and are being disposed off by this common order.

2. The petition