S. RAVINDRA BHAT, J.

1. In these proceedings under Article 226 of the Constitution of India, the assessee has questioned orders issued by the Assessing Officer (AO) proposing to re-open completed assessments for previous years. For AY 2000-01 (which is the subject matter of W.P.(C) 422/2006) the “reasons to believe” given by the AO, under Section 148 of the Income Tax Act (“the Act”) are inter alia, as follows:

“It has been judicially held by the Supreme Court in the cases of CIT Vs. Sterling Foods, 237 ITR 579 (SC), Cambay Electric Supply Industrial Co. Ltd. Vs. CIT, 113 ITR 84 (SC), CIT Vs. Pandian Chemicals Ltd., 233 ITR 497 (SC) and by Madras High Court in the cases of CIT Vs. Sundaram Industries Ltd., 253 ITR396 (Mad.) and in the case of CIT vs. Menon Impex (P) Ltd., (2003) 259 ITR 403 (Mad.) and by Kerala High Court in the case of CIT Vs. Cochin Refineries Ltd., (1982) 135 ITR 278 (Ker) that the used of the term "derived from" in the relevant provision of the Act indicates the restricted meaning to cover only the profits and gains directly accruing from the conduct of business undertaking.

5. The interest income of Rs. 1,73,09,543/- is in the nature of "income from oth