Singhvi, J.

1. Since a common point involving interpretation of sections 62 to 68 of the Finance Act, 1997 (hereinafter referred to as the 1997 Act) and section 297, read with sections 147 to 150, of the Income Tax Act, 1961 (hereinafter referred to as the 1961 Act) arises for adjudication in these petition, we arc deciding them by one order.

Facts:

2. Civil Writ Petition No. 12395 of 1998 - The petitioner made declaration of 865 gold coins and 128 kilograms of silver utensils under the Voluntary Disclosure of income Scheme, 1997 (the Scheme). She deposited Rs. 30,000 as tax and Rs. 1,200 as interest chargeable under the Scheme. Simultaneously, she also made an application for issuance of certificate under section 68(2) of the Finance Act, 1997 . Vide Annexure P3, the respondent refused to issue certificate to the petitioner on the ground that the disclosure of income relating to the assessment year 1961-62 cannot be treated as valid under the Scheme. The petitioner represented against this decision but failed to convince the respondent to change his decision. Therefore, she has invoked writ jurisdiction of this Court for quashing Annexures P3 and P5 and also for directing