(1.) THE petitioner in this petition took exception to and questioned notices dated May 29, 2001 (annexures marked as Exts. 13 to 17) issued under Section 147 read with Section 148 of the Income-tax Act, 1961 (hereinafter for short "the Act"), in regard to the assessment years 1991-92, 1992-93, 1993-94 and 1994-95 and the challenge to the notices is mainly on the ground that these have been issued after the expiry of four years from the end of the relevant assessment year even though the conditions as contemplated under Section 147 of the Act were not satisfied.
(2.) THE relevant facts briefly stated are :
(3.) HEARD Sri S.E. Dastur, learned senior counsel for the petitioner, and Sri S.K. Posti, learned counsel for the respondents.