JUDGMENT :

BHARGAV D. KARIA, J.

1. Heard Mr. Tushar Hemani, learned Senior Counsel with Mr. Hardik Vora, learned advocate for the petitioner and Mr. Varun K. Patel, learned Senior Standing Counsel for the respondent.

2. Both these petitions are arising for A.Y. 2016-17 and 2017-18 and Special Civil Application no. 4383 of 2022 be treated as lead matter.

3. Rule returnable forthwith. Mr. Varun K. Patel, learned Senior Standing Counsel waives service of notice of rule on behalf of the respondent.

4. Having regard to the controversy in narrow compass with the consent of the learned advocates for the respective parties, the matter is taken-up for hearing.

5. By these petitions under Article 226 of the Constitution of India, the petitioner has challenged the notice dated 30th March, 2021 issued by the respondent u/s. 148 of the Income Tax Act, 1961 (for short ‘the Act’) for A.Y. 2016-17 and 2017-18.

6. The brief facts of the case are that the petitioner is a public limited company engaged in the business of processing and manufacturing of various edible and non-edible oil and allied products.

6.1 The petitioner company has filed its return of income for A.Y. 2016-17 declaring total income of Rs