R. K. ABICHANDANI, J.

( 1 ) THE petitioners in these two petitions seek to challenge the notices dated 29th March, 1996 at Annexure "a" to the petitions, issued by the respondent Assistant Commissioner of Income Tax, proposing to reopen the completed assessment of the petitioners for the Assessment Year 1991-92. The facts of both these petitions are almost identical and the parties have filed their complete papers in Special civil Application No. 4201/96 and argued that case as a main matter. The asscssee of special Civil Application No. 4203/96 has challenged identical notice issued under Sec. 148 of the Act on identical grounds and the learned Advocates appearing lor both the sides have raised common contentions in both these petitions. The facts of Special Civil application No. 4201/96 are being set out and the facts of the other petition admittedly being almost identical, are not repeated.

( 2 ) THE petitioner had filed his return of income for the Assessment Year 1991-92 on 21st October, 1992, declaring his total income at Rs. 27,118/- alongwith the statement of income, notes appended thereto and other enclosures which are at Anncxure "c" to the petition. The case of the petit

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