Subhro 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 Section 148 of the Income-tax Act, 1961 ("the Act").
(2.) The writ petitioner-company was an assessee 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 Section 148 of the said Act proposing to reopen the assessments in respect of the aforesaid assessment years.
(3.) The present application under Article 226 was moved before this court challenging the said notices under Section 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.;