( 1 ) IN this petition under Article 226 of the Constitution, the petitioner has prayed for a writ of certiorari or any other appropriate writ for quashing the notice dated 29. 8. 2000 (Annexure "a") under Section 158 BD of the Income-tax Act, 1961 (hereinafter referred to as "the Act") issued by the Joint Commissioner of Income-tax, Special Range-2, Rajkot, the sole respondent herein.

( 2 ) THE facts leading to filing of this petition, briefly stated and as averred by the petitioner, are as under :-2. 1 the petitioner is engaged in the business of ship breaking at Alang, District Bhavanagar. In the course of its regular business, the petitioner sells materials to various parties from time to time and its purchasers at times pay cash or at times by their own cheques drawn on their own bank accounts or at times the cheques are obtained from other concerned persons with whom they may have transactions. The petitioner is concerned with realization of the sale price whether the payment is made by one mode or the other. The petitioners accounts are audited under the Income-tax Act as well as under the Companies Act. The search was initiated under Section 132 of the Act