JUDGMENT :

Om Prakash Shukla, J.

1. The petitioner challenges the correctness of the order dated 26th March, 2023 passed by the Assessing Authority under Section 148-A (d) of the Income Tax Act, 1961 (hereinafter referred to as ‘Act, 1961’) for the Assessment Year 2019-20 and the consequential notice dated 29th March, 2023 issued under Section 148 of the Act, 1961 for the Assessment Year 2019-20 as also the consequential proceedings undertaken subsequent thereto.

2. Shorn of unnecessary details, the brief facts, which led to the filing of this writ petition, are that the petitioner, a private limited company bearing PAN No. AAFCG0658J, is engaged in the business of developing and Managing hotels, motels, resorts, restaurants, cafes and other similar activities.

3. It is the case of the petitioner that for the purpose to achieve its business goal, the petitioner’s company has entered into an agreement to sale/lease dated 18.10.2011 with one Jayveer Singh in respect of his property, namely, ‘Deorhi Darwaza, Purna Mahal’ situated at Khasra No. 1533 in Village Maharaj Nagar, District Mahoba, U.P. (hereinafter referred to as the ‘property’) in distress sale. By the aforesaid agreement for s