( 1 ) IN this application, the petitioner has challenged three several notices issued under Section 148 of the Income-tax Act, 1961. Two of the notices are dated March 20, 1975, relating to the assessment years 1966-67 and 1967-68. The other notice dated February 20, 1978, is for the assessment year 1969-70. The ground of challenge is that the Income-tax Officer has no jurisdiction to initiate any proceeding under Section 147 (a) of the Income- tax Act, 1961, as the conditions precedent have not been satisfied.

( 2 ) THE reasons which have been recorded are identical for all the years which are to the following effect I"the assessee constructed a H. P. at 48-D, Muktaram Babu Street, Calcutta-7, during the accounting years 1964 to 1967 corresponding to the assessment years 1965-66 to 1968-69. The case was referred to the Executive Engineer (Valuation), Unit-II, Calcutta, and report of valuation since received. The total cost of construction up to the assessment year 1969-70 has been shown by the assessee at Rs. 4,20,000 including lift whereas the estimated value as per valuer is Rs. 5,06,900 including lift. There appears to have been no construction during the c