JUDGMENT

Akil Kureshi, J. - With the consent of the parties, this Petition which challenges a reopening notice under the Income Tax Act, 1961 (the Act), is being taken up for final disposal at the stage of admission.

2. This Petition under Article 226 of the Constitution of India, challenges a notice dated 27th March, 2018 issued by the Assessing Officer under Section 148 of the Income Tax Act, 1961 (the Act). The impugned notice seeks to reopen the Assessment for Assessment Year 2011-12.

3. Briefly, the facts leading to this Petition are as under:

(i) The Petitioner held 10% shares in one M/s. Samuel Dracup and Sons India Private Limited (the Limited Company) .

(ii) On 18th October, 2010, the Limited Company decided to voluntarily wind up and liquidate its business. This by the Limited Company passing resolution at the General Body Meeting of its share holders. It was resolved that the assets (including immovable property) remaining after paying of the liabilities, would be distributed between its share holders in proportion to their share holding.

(iii) Pursuant to the above, on 27th December, 2010, the Limited Company executed a sale deed, transferring the immovable property i.e.