I.S.Tiwana, J.

1. In these two Civil Writ Petitions Nos. 2279 and 2280 of 1975, the petitioner-assessee impugns two similar but different notices issued to her under Section 148 of the Income-tax Act (for short, "the Act") in order to reopen her I.T. assessments for the assessment years 1965-66 and 1966-67. The learned counsel for the parties are agreed that in view of the identity of facts and the contentions raised, these petitions can be disposed of through a common order and for that purpose, only the facts stated in C.W.P. No. 2279 need be adverted to. Further, the facts are not even in dispute.

2. During the yours noted above, the assessee had constructed a building on Railway Road, Ambala Cantt. The total cost of construction disclosed as per the valuation report was Rs. 1,54,400 though according to her accounts relating to the construction, the actual cost of construction was Rs. 1,43,077. The ITO accepted the valuation report as the actual cost of construction and treating Rs. 11,312 (the difference in the above-noted two amounts) as the undisclosed income of the assessee, distributed that as income of the two assessment years and finalised the assessments for the