(1.) In these two writ petitions, the notices issued under Sec.148 of the Income Tax Act, 1961 ('act' for short) both dated February 18, 2005 relating to the assessment years 1999-2000 and 2000-2001 are challenged. Even the objections raised by the assessee have been rejected by the assessing officer. Since the reasons for re-opening the assessment are identical, both the petitions are heard and disposed of by a common judgment.
(2.) For the sake of convenience, we set out the reasons recorded for re-opening the assessment for a. Y.1999-2000 which read as follows :
(3.) For the assessment year 1999-2000, the return of income was filed on December 29, 1999. On january 31, 2002, the assessment order under Section 143 (3) of the Act was passed determining income at rs.23,68,07,847/- after making various additions and disallowances.