G.S.Singhvi, J.

1. This petition involves adjudication of the petitioners challenge to notice Annexure P-1 dt. 27th Nov., 1984, issued by the ITO, Central Circle-II, Amritsar (respondent No. 2), under Section 148 of the Income-tax Act, 1961 (for short, "the Act"), proposing reassessment of its income.

2. The petitioner is a registered firm engaged in the business of rice shelling and manufacturing dal. A search was carried out at the business premises of the petitioner on 30th Nov., 1976. During the search operation, certain books of account and other documents are alleged to have been seized from its premises. The petitioner filed a return for the asst. yr. 1977-78 on 5th April, 1978, declaring a total income of Rs. 1,19,350. During the course of assessment, the petitioner was asked to file a certificate of the Central Bank of India, Majitha Mandi Branch, Amritsar (for short "the bank"), regarding stock pledged/hypothecated as on 30th Nov., 1976, and 31st March, 1977, for availing of overdraft facility. In reply, the petitioner gave out that the bank had not furnished the required certificate. Thereupon, respondent No. 2 sent a letter Annexure P-3 dt. 14th Dec., 1979, to t