M.C. Agarwal, J.

1. This is a petition under Article 226 of the Constitution of India preferred by the Kanpur Income Tax Bar Association through its Secretary Naveen Bhargava and Mukesh Srivastava a Chartered Accountant. The petitioners claimed to be legal practitioner in taxation laws and they challenge a clarification contained in paragraph 3 of a letter dated 25.11.1997 issued by Sri A. K. Batabyal, Member (Investigation) Central Board of Direct Taxes. The following reliefs have been claimed in this writ petition :

"(i) issue a writ, direction or order in the nature of certiorari calling for the record of letter/communication dated 25.11.1997 (Annexure-2) and the record of the decision of Government of India, if any, and to quash the same.

(ii) issue of writ, direction or order in the nature of mandamus directing the respondents, not to give effect to the 3rd paragraph of the aforesaid communication/letter dated 25.11.1997 (Annexure-2).

(iii) issue a writ, direction or order in the nature of mandamus restraining the Commissioner of Income Tax. Kanpur {Respondent No. 3) from reopening or reviewing the certificates which have already been granted under the provisions of the Sc