ORDER

1. The appellant is the transferee of immovable property situated at Sawai Madho Singh Road, Bani Park, Jaipur. In respect of that transfer, the requisite Form 37(1) was filed with the Income Tax Authorities on 9-3-1993 and a valuation report on 9-4-1993. On 21-5-1993, the appellant and the transferor of the said property were issued a notice by the office of the Appropriate Authority, Income Tax Department, New Delhi, to attend a hearing before him at Jaipur on 31-5-1993 at 9.30 a.m. The notice invited the attention of the addressees to a sale instance, namely, the auction of another property on Sawai Madho Road on 3-10-1991. Based upon that sale instance, the notice informed the addressees that the apparent consideration of the transaction in appeal was low. The notice was sent from Delhi to the appellant at Jaipur by speed post and the photocopy of the envelope shows that it was posted only on 24-5-1993. It is averred by the appellant that it was received by it on 26-5-1993. On 29-5-1993, a letter was written to the Appropriate Authority on behalf of the appellant which requested him to supply to the appellant a copy of the deed in respect of the sale instance and site pl