Shubhro Kamal Mukherjee, J. - (1.) This appeal is directed against an order dated December 18, 1992 passed by a Learned Single Judge of this court whereby the Learned Single Judge allowed an application under Article 226 of the Constitution of India and accordingly, quashed notices under Sec. 148 of the Income Tax Act, 1961 (the said Act in short). The writ petitioner -company was an assess under the said Act and admittedly, they have submitted their returns of income for the assessment years 1972 -73 and 1973 -74. Although orders of assessment for the said years were passed by the Income Tax Officer concerned, subsequently the Income Tax Officer issued notices under Sec. 148 of the said Act proposing to reopen the assessments in respect of aforesaid assessment years.
(2.) The present application under Article 226 of the Constitution of India was moved before this court challenging the said notices under Sec. 148 of the said Act contending, inter alia, that the Income Tax Officer was really harassing the assessee and there was no bona fide reason to reopen the assessments.
(3.) The Learned Single Judge by the order impugned quashed the aforesaid notices holding that the reasons for reopening the assessments did not provide a live -link between the materials and the belief.;