A.P. Sen, J.-This is a petition by the official liquidator acting for the Bharatpur Oil Mills (P.) Ltd. (In liquidation) for the issue of a writ of certiorari, prohibition or other appropriate writ, direction or order under Article 226 of the Constitution, by which the petitioner challenges the validity of a notice dated September 27, 1972, issued by the ITO, “A” Ward, Kota, under Section 148 of the I.T. Act, 1961.

2. During the assessment year 1966-67, the previous year of which corresponded to the year ended on March 31, 1966, the official liquidator effected sales of capital assets of the company in liquidation, i.e., machinery, plants, etc., on August 5/6, 1965, under the order of the High Court for a sum of Rs, 6,35,000. It appears that one-fourth of the auction price was deposited on August 9, 1965, and the company accepted the bid on August 18, 1965. In December, 1965, the official liquidator sold a truck and a tank for Rs. 3,275 and Rs. 1,100, respectively. The ITO, Companies Circle I, Jaipur, having come to know about the transfer of the capital assets of the company, issued a notice dated July 24/25, 1967, under Section 148, with a view to bring to tax in the han