R. JAYASIMHA BABU, J.

The petitioner is aggrieved by the issuance of the notice by the respondent under s. 148 of the IT Act. That notice was issued on 18th December, 1996, and it is in respect of the asst. yr. 1989-90. The notice was issued more than six years after the end of the relevant assessment year.

2. The petitioner contend that the precondition for the issue of such notice not having been satisfied, the proceedings sought to be initiated by the insurance of that notice is wholly without jurisdiction. The petitioner has, therefore, sought a writ of prohibition to prohibit the respondent from taking any proceedings pursuant to that notice.

3. The petitioner is a company carrying on business in the manufacture and sale of industrial V-belts, automotive fan belts and oil seals, conveyor belting and installation of material handling systems. The petitioner filed its return of income for the asst. yr. 1989-90 relevant to the accounting year ended 31st March, 1989, on 11th September, 1989. Revised returns were filed on 27th April, 1990, and 10th May, 1990 and in the last of the returns income of Rs. 20, 64, 850 was admitted.

4. The petitioner's case was selected for a de