By these writ petitions, orders under Section 201/201(1A) of the Income Tax Act, 1961 and consequential re-assessment proceedings under Section 148 are challenged.

2. Learned Advocate General for the petitioner submits that the total tax demand under the impugned orders under Section 201/201(1A) is about Rs.126 crores across the relevant assessment periods. He points out that two rectification petitions were filed in respect of the aggregate liability of about Rs.50 crore. The first rectification petition was filed on 05.06.2024 and the second on 20.06.2024. The rectifications were filed in respect of interest payments made to the University of Madras, CMDA, educational institutions and the like. He submits that relevant certificates have been submitted in respect of most of these entities. He seeks expeditious disposal of these rectification petitions. As regards the remaining sum of about Rs.70 crore, he submits that the petitioner is ready to remit a reasonable portion thereof to protect revenue interest in the interregnum.

3. Dr.B.Ramaswamy, learned senior standing counsel, who appears on behalf of the respondents, submits that the time limit specified in Section 154 of the