During the course of survey operations, various evidences were collected which went on to prove that the sites of management and control of the petitioner is in India at Unit-4, 7^th Floor, Crest Building, Ascendas IT Park, CSIR Road, Taramani, Chennai-600 113, i.e., the premise of Watanmal India, in association with all the functions related to the business activity of the petitioner, which are being carried out there and there exists a business connection as per Explanation 2(a) of Section 9(1) of the IT Act. The petitioners  have not filed the return .   v The petitioner has approached this Court at initial stage only on the ground that the respondents have no authority to invoke Section 147 of the Act. However, perusal of the reasoning given in the show cause notice, it is suffice to arrive a conclusion that there are materials and evidences enough to allow the Department to proceed with the issues and adjudicate the same based on the materials and evidences available and by affording opportunity to the petitioner. Court held that  the petitioner could not able to establish any acceptable ground for the purpose of interference at the stage of issuance of a notice under Section 148 and the issuance of show cause notice and contrarily the respondents could able to establish that sufficient materials are available on record, which were considered and scrutinised and a finding on such analysis is also recorded in the impugned show cause notice, there is no reason whatsoever to interfere with the actions of the respondent and thus, all the writ petitions fail and stand dismissed. In view of the fact that the respondents had already completed the assessment process and passed an assessment order and kept the same in a sealed cover, the respondents are permitted to open the sealed cover and communicate the assessment orders to the petitioner without any further delay enabling the petitioner to proceed further, if any grievance exist. Accordingly, all the writ petitions  are dismissed. (AY. 2006 -07 )