( 1 ) THE petitioner purchased a plot of laud being premises No. 42b, Garcha Road, subsequently numbered and renamed as 51e, Gariahat Road (hereinafter referred to as the "said premises" ). The area of the said premises has been stated to be 1 bigha, 19 cottahs, 11 chitaks and 3 sq. ft. Such purchase was made from one Smt. Latika Ghose of 80/5b, Lansdown Road, Calcutta. The petitioner has stated that in or about July, 1966, she started construction of a building on the said premises and such construction was completed in or about October, 1968, at a total cost of about Rs. 2,46,363. 11. It has also been stated by the petitioner that she was all along and since the assessment year 1958-59, assessed under the provisions of the W. T. Act, 1957 (hereinafter referred to as the "said Act" ).

( 2 ) IT has further been stated by the petitioner that in the course of assessment proceedings under the provisions of the I. T. Act, 1961, for the assessment year 1967-68, she furnished to the ITO concerned, who is also the WTO concerned, being respondent No. 1, the details of the cost of construction of the building, along with a valuation report dated 21st November, 1968, from M/s