S. Ravindra Bhat J. (Open Court)

1. The petitioner seeks a direction for quashing of a notice under Section 148 of the Income Tax Act issued by Revenue on 26.04.1995 in respect of the Assessment Year 1991-92.

2. It is urged that in respect of the above Assessment year, the petitioner/assessee had filed its return on 31.12.1991. During the pendency of the assessment proceedings, the assessee’s premises were subjected to search on 13.10.1992. In the light of the materials found by the Income Tax Authorities, a questionnaire was addressed to the assessee on 21.05.1993. Reliance is placed by the assessee/petitioner upon various proceedings of the Income Tax Authorities in respect of Assessment Year (AY) 1991-1992, specially the order sheets made after 21.05.1993. It is argued that the nature of queries sought in response to its reply do illustrate and clearly brings out that the Revenue wishes information with respect to a host of matters including deposits made by four concerns i.e. M/s. Maha Shveta Traders Ltd., M/s. Remico Testiles (P) Ltd., M/s. Marvex Enterprises (P) Ltd. and M/s. Prabhat Enterprises (P) Ltd. The Revenue had also put to the Managing Director of the assesse