ORDER :

1. The petitioner is aggrieved by the impugned order dated 26.03.2018 passed by the first respondent under Section 264 of the Income Tax Act, for the Assessment Year 2014-2015.

2. By the impugned order, the first respondent has rejected the application filed by the petitioner for revising the Assessment order dated 21.12.2016 passed by the second respondent under Section 143(3) of the Income Tax Act.

3. Challenge to the order dated 21.12.2016 of the second respondent before the first respondent was primarily on the ground that petitioner has not claimed depreciation under Section 32 of the Income Tax Act, 1961 in respect of four of its properties which were later sold during the course of Financial year 2013-2014 pursuant to an auction and then the petitioner cannot be perforce given the benefit of Section 15(2) of the Income Tax Act, 1961 instead of indexation under Section 48.

4. It is the case of the petitioner that the last return that was filed by the petitioner was for the Assessment year 2001-2002. Thereafter, for the next 11 years, the petitioner had not filed returns as was neither having any income nor loss from the business.

5. It is the further case of the petitioner