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JUDGMENT Sanjeev Sachdeva, J. - The petitioner has filed the present petition challenging the order dated 23.08.2010 rejecting the objections filed by the petitioner against two notices, both dated 30.03.2010, under Section 148 of the Income Tax Act, 1961 seeking to re-assess the income of the petitioner for the assessment years 2005-06 and 2006-07. 2. The petitioner is a charitable trust and runs hospitals and schools. 3. The assessment for the assessment years 2005-06 and 2006-07 was originally completed under Section 153A/143(3) of the Income Tax Act, 1961 (hereinafter referred to, 'the Act'). 4. For the assessment year 2005-06, the assessment was framed on 31.12.2008 at a loss of Rs.1,77,03,110/- and for the assessment year 2006-07, the assessment was framed on 31.12.2008 at a loss of Rs.1,53,90,490/-. 5. On 30.03.2010, i.e., before expiry of four years of the assessment year 2005-06 and 2006-07, notices were issued to the petitioner under Section 148 of the Act seeking to reassess the income of the Petitioner for the said assessment years. In reply to the said notices, the petitioner stated that the original return of income may be treated as returns filed in response to the notice under Section 148 of the Act. The Petitioner further requested for the supply of reasons to believe recorded for issuance of the said notices. 6. The following reasons were supplied for the respective assessment years: Assessment Year 2005 - 06 '30.03.10. Reasons For Issuance of Notice Under Section 148 of The Income tax Act 1961 in the Case of M/S Mahashay Chunnilal Charitable Trust For The A.Y. 2005-06 The assessment under section 153(A)/143(3) of the I.T. Act 1961 was completed in this case on 31.12.2008 at assessed loss of Rs.1,77,03,110/-. The assessee had invested in Property "MDH School Building", Byadgi, District Haveri, Karnataka. The property was referred for valuation u/s 142(A) to the Valuation Officer, Bangalore. The Valuation Report of the said property has been received vide letter dt. 19.06.09 received in this office on 29.06.09. The valuation officer has worked out the value of the property at Rs.75,86,800/- against the declared value of Rs.24,41,776/- lakhs as…

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