( 1 ) ALL these Special Civil Applications list of which is annexed as schedule to this order, raise a common issue in similar set of facts relating to each case, hence they are being heard and decided together by a common order.

( 2 ) THE dispute in each case relates to initiation of proceedings for reopening assessment for the assessment year 1984-85/85-86 by issuing notice under Section 148 in March 1991 and the principal contention raised in all these cases is whether the proceedings have been initiated within the pereiod prescribed under the Act. It is urged by Mr. J. P. Shah, learned counsel for the petitioner assessees in all these cases, that there has been no failure on the part of the assessee to make a return under Section 139 or failure to make a return in response to the notice issued under subsection (1) to Section 142 or under Section 148 nor there is any failure on the part of the assessee to disclose fully and truly all material facts necessary for the assessment for the assessment years in question. That being so, assessment for these assessment years having been duly completed, proceednigs for reassessment, if any, could not have been initiated, after