Judgment :- These two writ petitions are filed by two different assessees to income tax under the Income tax Act, 1961 (for short ‘the Act’). Both the petitioners owning rubber plantations. The income from the said plantations, a portion of which was assessed to income tax under the Act by invoking the provisions of section 147 of the Act and the by issuing notices under section 148 of the Act. The assessment orders (Exts.P2 and P3 in O.P.No.10458/01 and Exts.P3 to P5 in O.P.No.10460/02) and demand notices (Ext.P4 in O.P.No.10458/01 and Ext.P5 in O.P.No.10460/01) were issued. The petitioners have impugned the said orders. 2. I have heard the learned counsel on both sides. These two issues are covered by the judgment dated 2.7.2004 in O.P.No.4939/1999 and connected cases. In the said judgment this court referred to the Circular (261 ITR statute 158) issued by the Central Board of Direct Taxes, New Delhi wherein it is specifically clarified that in respect of the assessment years prior to 2002-2003 re-opening/revision of assessments either under section 147 or under section 263 of the Act need not be made provided the assessees have paid tax on the entire income of the assessees to the Agricultural Income tax Department. 3. In the circumstances, I am of the view that these two writ petitions can also be disposed of on those lines. Accordingly there will be a direction to the 1st respondent in both these cases to verify as to whether the petitioners had already remitted tax on the entire income of the petitioners to the Agricultural Income tax Department. If the petitioners establish the same these assessment orders and demand notices passed by the Income tax Department which are impugned in these two writ petitions will stand set aside. The 1st respondent will afford an opportunity of being heard to the petitioners to establish the same. Writ petitions are disposed of as above.