JUDGMENT

M. S. Sonak, J. - Heard the learned counsel for the parties.

2. The learned counsel agree that a common judgment and order can dispose of both these petitions because the issues of law and fact are almost identical. The Petitioner in Writ Petition No.48 of 2022 is the wife of the Petitioner in Writ Petition No.47 of 2022. Given Section 5A of the Income Tax Act, 1961, separate returns were filed by the wife and the husband for the Assessment Year 2016-2017. Therefore, the issues of law and facts raised in both these petitions are identical. Accordingly, writ Petition No.47 of 2022 is taken the lead petition.

3. The Petitioners filed their income tax returns under Section 139(1) for the Assessment Year 2016-2017. This was followed by a revised return of income on 18.01.2017, declaring a total income of ?1,17,69,130/-. On 11.08.2017, their cases were considered for limited scrutiny, and a notice under Section 143(2) was issued to them.

4. Notice dated 11.08.2017 stated that the following issues have been identified for examination:

"i. Whether value of consideration for computation of capital gains has been correctly shown in the return of income.

ii. Whether deduction from capital