( 1 ) THE petitioner-company entered into an agreement to purchase a flat at premises No. 70d, Hindustan Park, Calcutta (referred to as "the flat") on September 22, 1992. The total consideration price was stated to be Rs. 28. 50 lakhs. On September 29, 1992, the petitioner-company and the owner of the flat being respondent No. 5 herein filed Form No. 37-I before the appropriate authority under Section 269uc of the Income-tax Act, 1961 (referred to as "the Act" ). On October 13, 1992, an inspection was held and detailed scrutiny made in respect of the transaction in question. The particulars together with instances of five other properties, their description, locality and values were submitted to the appropriate authority on November 4, 1992, along with a report of the executive engineer. The executive engineer was of the view that the consideration for the sale of the flat in question had been understated.

( 2 ) ON November 20, 1992, notice was issued to the petitioner-company requesting it to show cause why the flat in question should not be purchased under Chapter XX-C of the Act as the apparent consideration shown by the petitioner appeared to be understated as co