( 1 ) CHALLENGE in this writ petition is to the notice dated 30. 3. 1999 issued under Section 148 of the Income-tax Act, 1961 and served on the assessee on 1. 4. 1999 and to the notices issued under Sections 143 (2) and 142 (1) of the act dated 24. 1. 2001. Incidentally, challenge is also made to the order passed by the district Valuation Officer (in short, DVO), dated 19. 2. 1999 under Section 55a of the act read with Section 16f of the Wealth-tax Act (inshort the WT Act ). It is to be noted that earlier the petitioner had filed a writ petition (No. 1021 /2000) questioning the notice issued on the purported ground that what "constitute reasons to believe" for initiation of the proceedings was not communicated. By order dated 10. 2. 2000 direction was given to the respondent to furnish a copy of the reasons recorded under Section 148 of the Act. After the same have been furnished the present writ petition has been filed questioning legality of the action taken.

( 2 ) FACTUAL position in a nutshell is as follows: on 25. 3. 1997, assessee filed its return of income for 1995-96. Long term capital loss of Rs. 36,28,313. 00 in respect of properties situated at Delhi and Mu