1. - The Rajasthan State Electricity Board (for short, "the RSEB"), the petitioner herein, has challenged the levy and imposition of additional tax under section 143(1A)(a) of the Income-tax Act, 1961 (for short, "the Act"), and the consequent issuance of intimation dated February 12, 1992, amended on February 28, 1992, and the demand of Rs. 7,67,68,717, being illegal, unauthorised and in violation of the principles of natural justice, as null and void and has sought a writ of certiorari quashing the aforesaid demand.

2. The RSEB submitted its return of income on December 30, 1991, for the financial year 1990-91 relevant to the assessment year 1991-92. In the said return, it has shown a loss of Rs. 4,27,39,32,972. For the aforesaid assessment year, the RSEB suffered a loss as per revenue account amounting to Rs. 1,68,39,37,000. It also claimed depreciation of Rs. 3,33,77,70,317 and, after disallowing inadmissible expenditure, the aforesaid total loss was shown in the return filed as aforesaid. An intimation under section 143(1A)(a) of the Income-tax Act was issued to the RSEB by the Deputy Commissioner of Income-tax (Assessment), Special Range-II, Jaipur, dated February 12,