( 1 ) RULE. Service of rule is waived by learned counsel for the respondent.

( 2 ) THE petitioner challenges notice issued by the respondent u/s 148 on 18. 2. 1997 in respect of A. Y. 1993-94. The reasons which are required to be recorded before issuing notice when demanded by the assessee were disclosed to the assessee by letter dated 16. 4. 97, Annexure F, which reads as under:-"as per provision of section 147 of the I. T. Act, explanation 2 (c) (iv), deduction u/s 80hhc claimed at Rs. 7,07,64,720. 00 has been wrongly claimed as you have not included an amount of 142. 62 crores of export turnover in respect of marine division as total turnover of business, while claiming deduction u/s 80hhc of the I. T. Act which is not as per provision of the I. T. Act. "the petitioner challenges the issuance of notice, inter alia, on the grounds that the reasons show that impugned notices proceeds on mere change of opinion on reappreciation of evidence which is already on record. In respect of Marine Division the assessee has not claimed export benefit u/s 80hhc of the Act, the erroneous calculation of which is considered to be ground for reopening the completed assessment. The reco