AJIT K. SENGUPTA, J.

( 1 ) THIS appeal is directed against the judgment and order dated May 17, 1989, passed by the court of the first instance on a writ petition filed by the appellant. In the said writ petition, Smt. Uma Devi Jhawar, the appellant/writ petitioner challenged the validity of a notice dated March 31, 1976, issued by the Income-tax Officer, "k" Ward, Companies District-I, Calcutta, under Section 148 of the Income-tax Act, 1961 ("the Act"), for the assessment year 1967-68. By the aforesaid judgment and order dated May 17, 1989, the said writ petition was dismissed.

( 2 ) SHORTLY stated, the facts are that in the year 1964, the writ appellant purchased a piece of land at No. 24b, Carcha Road, Calcutta (also numbered as 51e, Gariahat Road, Calcutta), for a consideration of Rs. 86,000. In July, 1966, the appellant started construction of a house thereon which was completed in October, 1968. The said building was constructed at a total cost of Rs. 1,46,363. 11 paid by the appellant in four years from 1967 to 1970.

( 3 ) IN the course of the assessment proceedings for the said assessment year 1967-68, the appellant furnished details of the said cost of construe tion in

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