JUDGMENT :

(Neela Gokhale, J.) :

1. Rule. Rule made returnable forthwith. By consent, Petition is taken up for final hearing at the admission stage.

2. Petitioner assails notice dated 30th July 2022 issued under Section 148 of the Income Tax Act, 1961 (“Act”), approval under Section 151 of the Act granted by the Principal Chief Commissioner of the Income Tax (“PCCIT”), Mumbai, communication/letter dated 28th May 2022 seeking explanation and details from Petitioner to facilitate the Jurisdictional Assessing Officer (“JAO”) to pass an order under Section 148A(d) of the Act, Order dated 29th July 2022 passed under Section 148A(d) of the Act for Assessment Year ("AY") 2015-16, notice dated 31st May 2021 under Section 148A(b) of the Act, notice dated 21st April 2021 for AY 2015-16 under Section 148 of the Act.

3. Facts giving rise to the present Petition are that Petitioner, a private company engaged in the business of undertaking real estate projects, sold a plot of land situated at Raigad District to one Regency Nirman Limited by a registered agreement to sell dated 7th October 2011 for a consideration of Rs.18 Crores. The property was valued at Rs.16.50 Crores for the purpose of stamp du