( 1 ) IN 1964, petitioner Harnam Sinph Suri purchased a plot of land No, 1/30, Punjabi Bagh, on which he later on constructed a house. On 17. 1. 1972, he filed an income-tax return for 1971-72. In the accompanying statement, he stated that the said house was self-occupied and was sold on 15. 1. 1971. The capital gain out of the sale was Rs. 1,31, 884. 00 which was utilised for purchase of a residen- tical flat in Asha Deep on 18. 1. 1971. So in column 5 of the return under the caption capital gains he entered the word none . In the verification, the petitioner solemnly declared that to the best of his knowledge and belief the information given in the return and the annexures and the statement accompanying it is correct and complete and the amount of total income and other particulars shown are truly stated. In the course of assessment proceedings, the petitioner filed an affidavit on 18. 2. 1972 stating inter alia that prior to its sale, he was living in the house for more than two years. The ITO. by his assessment order dated 6. 3. 1972 completed the assessment. No tax on capital gains was levied on account of the aforesaid statement in virtue of section 54 of the Inc