Puttaswamy, J.—An house property bearing No. 2 situated on Artillery Road, Civil Station, Bangalore City, measuring about 627 sq. mts. was originally owned by one Sadiq Hussain of Banglore City, who on June 15, 1981, transferred the same to the petitioner for a sum of Rs. 1,80,000. On an examination of the said transfer, the Inspecting Assistant Commissioner of Income Tax (Acquisition Range), Bangalore, ("IAC"), being of the opinion that the fair market value of the property exceeded the apparent consideration stated in the instrument of transfer by more than 15% had issued notice No. CR 62/30399/81-82 dated December 18, 1981 (annexure G) to the transferor and transferee under s. 269D(1) of the I.T. Act of 1961 (Central Act 43 of 1961) ("the Act"), proposing to acquire the property for the Government under Chapter XXA of that Act. In this petition under art. 226 of the Constitution, the petitioner has challenged the said showcause notice principally on two ground and they are (i) that the proceedings had not been initiated by the IAC within the permitted time and (ii) that the transaction being real and genuine, there was no justification to initiate proceedings under the A