1. Heard the learned counsel appearing for the petitioner, as well as the learned counsel appearing on behalf of the respondents.

2. It has been stated that the petitioner had filed the return of income, for the assessment year 2009-2010, on 9.11.2010, admitting a total income of Rs.1040/- and it had been processed, under Section 143(1) of Income Tax Act, 1961. Subsequently, the case of the petitioner was selected for scrutiny, under the computer assisted scrutiny system, and a notice had been issued, under Section 143(2) of the said Act.

3. It has been further stated that, during the previous assessment year, the petitioner had sold his family property, in Akkinampattu Village, Palur Post, Chiyyur Taluk, Kanchipuram District and had received his share of Rs.49,89,450/-, out of the sale proceeds. The property which had been sold was agricultural land. The petitioner had invested a sum of Rs.26,74,800/- towards the purchase of residential house plots, in Kancheepuram District. A certificate had been obtained from the Village Administrative Officer concerned stating that the property in question was agricultural land. However, the second respondent, without considering t