( 1 ) THIS writ petition has been filed for a writ of certiorari for quashing the impugned notice dated november 20, 1998 (annexure 4 to the writ petition), issued under Section 148 of the Income-tax act, 1961. Counter and rejoinder affidavits have been exchanged. We have heard Sri V. B. Upadh-yay, learned senior advocate, and Sri Yashwant Verma, learned counsel, for the petitioner, as well as learned departmental counsel for the respondents.

( 2 ) THIS writ petition being Writ Petition No. 181 of 1999, relates to the assessment year 1988-89, whereas connected Writ Petition No. 182 of 1999, relates to the assessment year 1989-90 and writ Petition No. 183 of 1999, relates to the assessment year 1990-91. Since the petitions are similar in nature they are being disposed of by a common judgment.

( 3 ) THE petitioner is a foreign company incorporated in France. It is engaged in the business of oil exploration and providing expertise and assistance in the said field throughout the world.

( 4 ) DURING the relevant assessment year, the petitioner-company was operating under three contracts with the Oil and Natural Gas Commission. These contracts were for drilling operation by