S.S.Sandhawalia, Prem Chand Jain and M.R.Sharma JJ.

1. A plot of land measuring approximately 16 marlas (3,360 sq. ft.) was sold by Guru Nanak Public Welfare Trust, Milap Chowk, Jullundur, for a sum of rupees forty thousand to M/s. Amrit Sports Industries, Basti Nau, Jullundur, the respondent-assessee in this case, vide sale deed No. 3809 dated September 8, 1977. Shri Nirmal Singh, Inspector, made his report dated April 20, 1978, to the effect that the plot in dispute was of the market value of Rs. 1,32,000 on the date of the sale. The Competent Authority initiated proceedings under Section 269D of the I.T. Act, 1961 (hereinafter referred to as "the Act"), and the relevant notice was published in the Official Gazette on June 3, 1978. It appears that in the meantime the assessee-respondent had built some shops on this plot of land and had let them out to some tenants. The actual notice of the proceedings was in fact served upon the assessee-respondent, but no such notices were served upon the tenants, who were occupying the shops built on the plot in dispute. The Competent Authority, vide its order dated March 21, 1980, held that the case fell under Section 269F(6) of the Ac