(1.) Petition is filed impugning a notice dated 29 th March 2019 issued under Sec. 148 of the Income Tax Act 1961 (the Act) for A.Y.-2012-13 and also impugning an order dated 5 th September 2019, rejecting the objections raised by petitioner.
(2.) Petitioner, engaged in the business of construction and development of properties, had admittedly filed on 31/8/2012 its return of income for A.Y.-2012-2013. The same was processed under Sec. 143(1) of the Act and later was scrutinized under Sec. 143(3) of the Act. On 29 th March 2019, the impugned notice under Sec. 148 of the Act was issued. The reason to believe was provided on 4/4/2019 which reads as under:
(3.) As per the reason to believe, respondent no.1 has raised two issues, viz, (a) there was a difference of Rs.164,95,76,770.00 between closing balance for A.Y.-2011-12 and the opening balance for A.Y.-2012-13 in the work in progress figures indicated and, (b) from ITS Data it can be seen that petitioner had sold property of Rs.20,98,30,400.00 but no sale has been booked for A.Y.-2012-13.