NV Vasudevan, Judicial Member. - These are appeals by the assessee against a common Order dated 29-1-2004 of Commissioner of Income-tax(A)-VI, New Delhi relating to the assessment years 1994-95 and 1995-96.

2. The first ground of challenge in these two appeals is to the validity of initiation of reassessment proceedings by invoking the provisions of section 148 of the Income-tax Act. The facts, which are necessary for adjudication of the aforesaid ground of appeal of the assessee are as follows. The assessee is a Private Limited Company carrying on business of rendering consultancy in the field of architecture. They are also engaged in the business of rendering consultancy services in the field of engineering and planning etc. For the assessment year 1994-95, the assessee filed a return of income declaring income of Rs. 17,41,030 on 30-11-1994. By letter dated 8-9-1995 the Assessing Officer called upon the assessee to file certain details. The assessee had in the computation of income claimed depreciation of Rs. 54,42,165. A depreciation chart had been enclosed along with the computation of income. Under the head plant and machinery costing less than Rs. 5,000 the assessee had