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Prefatory Facts:

1. These are writ petitions concerning Assessment Years (AYs) 2016-17 and 2017-18.
2. A singular but common issue has been raised in these writ petitions, which is whether the notices issued to the petitioners under Section 148 of the Income Tax Act, 1961 [hereafter referred to as the "1961 Act"] are sustainable in law having regard to Clauses (a) and (b) of Section 149(1) of the 1961 Act?

18. Before we proceed further, we may note that based on the agreement arrived at between the counsel representing both the assesses and revenue, we had indicated that we would allude to the dates and events concerning W.P.(C) 12281/2022, titled, M.R. Auxiliary Services Private Limited vs. ITO & Anr. and W.P.(C) 15121/2022, titled South East UP Power Transmission Company Limited vs. Deputy Commissioner of Income Tax, Central Circle-19, Delhi & Ors. steering clear of the prefatory facts which have already been referred to hereinabove, since the issue which has arisen for consideration is a pure question of law and the judgment rendered by us would operate in rem and cover all assessees.