Hon’ble Surya Prakash Kesarwani, J.—In this bunch of writ petitions, the petitioners have challenged the constitutional validity of amendments in Section 80 HHC(3) of the Income Tax Act, 1961 brought by the Taxation Laws (Amendment) Act, 2005 as well as the validity of the impugned notices/orders.

Facts of the Case

2. The facts involved in these writ petitions are similar and as such the facts of the Writ Petition No. 523 of 2006 are noted in detail and this writ petition is being taken up as a leading writ petition. The facts of the rest of the writ petitions are being noted in brief.

3. In Writ Petition No. 523 of 2006 the petitioner is a limited company engaged in manufacturing of Mentha Oil, Menthol Powder, Menthol crystal, Dementholized Oil, Peppermint oil and Di-hydromyrcenol and their bye-products. The petitioner’s factory is situate in district Rampur established in the year 1997. It is stated in paragraph Nos. 10 and 11 of the writ petition that it has been the basic policy of Government of India to make the export competitive and to neutralize the incurrence of custom, excise duties, and other taxes by the schemes known as Duty Drawback Scheme (for short DDS), Adv