Akil Abdul Hamid Kureshi, J.

1. These petitions arise in common background. They have been heard together and would be disposed of by this common judgment. For convenience, we may refer to the facts arising in SCA No. 17307 of 2015. The petitioner is a company registered under the Companies Act. For the asst. yr. 2011-12, the petitioner filed return of income on 17th Oct., 2011 declaring nil income. Such return was processed under s. 143(1) of the IT Act, 1961 ("the Act" for short) and thus accepted without any scrutiny. The AO later on issued impugned notice Dt. 2nd March, 2015 under s. 148 of the Act seeking to reopen the assessment of the petitioner for the said asst. yr. 2011-12. He supplied to the petitioner the reasons recorded for issuing such notice, which read as under:

"In this case, on verification of records, it is found that the assessee is a private limited company engaged in the business of Manufacturing of Ceramic Tiles. On the basis of information available with this office, assessee company had issued its shares at huge premiums during financial year 2010-11. On verification of "Part-A-BS" of return of income filed by the assessee company, it is found that