Pinaki Chandra Ghose, J. - (1.) The writ petitioner in this application has challenged six notices all dated July 29, 1994, issued by the respondent-Department under Section 148 of the Income-tax Act, 1961 (hereinafter referred to as "the said Act"), for reopening the assessments under Section 147 of the said Act, 1961, for the assessment years 1984-85 to 1989-90. The petitioner has also challenged approvals and/or satisfactions of respondent No. 2, the Commissioner of Income-tax, West Bengal, Range-VIII, Calcutta, under Section 151(1) of the said Act in respect of all the said assessment years. The petitioner has challenged the said notices under Section 148 of the said Act on the ground that the conditions precedent for the assessment under Section 147 of the said Act read with Section 148 of the said Act have not been satisfied and the requirements of law have not been fulfilled.
(2.) The contentions of learned counsel appearing on behalf of the petitioner are as follows :
(3.) The assessments for the assessment years were all completed under Section 143(3) of the said Act and the petitioner disclosed fully and truly all material facts necessary for the said assessments. The said assessments have become final after the disposal of the said appeals by the final appellate authority under the said Act.;