1. That since 1987 Petitioner sent several Letters to Income Tax Department, about possible use of black money by the said unscrupulous Businessman turned Mafia Leader Sanjay Kumar Jhunjhunwala, his associates and relations and their Companies, but under political influence, no action were taken by the Income Tax Department. The matter were placed in the notice of the all concerned authorities including the Prime Minister, Finance Minister(s) and Revenue Secretary, Chairman of Central Board of Direct Tax and various other authorities, all by Registered Post or under acknowledgements but in vain. Said Mafia Leader, his relation and associates and their Companies used black money of more than Five Hundred Crores of Rupees, in their purchase of Properties worth of more than Five Hundred Crores of Rupees and then sell of constructed properties. To establish modus operandi applied by them, in use of black money, Petitioner emphasis one particular transaction with complete details. The details of facts relates to one such transaction executed in serious violations of the Income Tax Act were referred by the Petitioner before respective authorities, but under criminal misconduct and / or political influence or otherwise, action were not taken by any authority of the Government of India, which is a strong evidence that respective authorities virtually acted to protect the huge black money hold by the said Mafiadom. In the aforesaid matter the said Mafia Mr. Sanjay Kumar Jhunjhunwala openly as per record and also as per recent Supreme Court Judgment, violated the provisions of the Income tax Act, in various ways. With knowing full intentions to violate the respective provision of the Income Tax Act respective transactions were divided into Six Deeds, being executed in favour of two of the Companies of said Mafia Sanjay Kumar Jhunjhunwala. The facts of the non-action by the authorities can be explained in the following manner: -

1. That on 25^th August 1989, one / single Notice in the English Daily Newspaper from Calcutta (Now Kolkata) namely The Telegraph was published by one Messers Pankaj Shroff & Co, Advocates, having their address at 7B, Kiran Sankar Roy Road, Calcutta-700 001 interalia that his clients "Surabhi Properties Pvt. Ltd., and Tripti Properties Ltd., both having their Registered Office at No. 9/1, Lower Rawdon Street, Calcutta have agreed to purchase premises no.53, Ramtanu Lahiri Sarani (formerly 24A, Diomond Harbour Road and originally Plot No.42 of Block "C' New Alipore), Calcutta measuring 10 Kottahs 02 Chittacks 38 Sft. from Mr. Pranab Dutta Chowdhury, Smt. Purabi Dutta Chowdhury and Dr. (Miss) Shyamali Dutta Chowdhury all of 53, Ramtanu Lahiri Sarani, Calcutta." Photocopy of the said Notification is annexed herewith and marked as "Annexure: E-1".
2. That within six months from aforesaid Notice, on or about 23^rd February 1990 the Income Tax Department, West Bengal, published a Notification on several Newspapers for GRAND AUCTION SALE under the signature of Mr. N.R. Sivaswamy, the then Chief Commissioner (Technical), West Bengal, with reference to several properties, including one "Vacant land measuring 5 cottahs more or less 12" wide common passage from the main road, forming part of plot no.386A Block "C', New Alipore, Calcutta and renumbered 23A, 386A, Diomond Harbour Road, Calcutta." The said property referred in the Notice of the Income Tax Department was and is situated in the same locality of the properties referred in the said Notice of Messers Pankaj Shroff & Co, Advocates. In the notification of the Income Tax Department "Reserve Price Rs.18,27,000/-" was mentioned, for that particular properties. According to such reserve prices, fixed by the Income Tax department, the amount of Rs.3,65,400/- arises for per cottah of land. This is a matter of the fact that subsequently said Mr. N.R. Sivaswamy, the then Chief Commissioner (Technical) Income Tax Department, West Bengal, was promoted as the Chairman of the Central Board of Direct Taxes, under the Ministry of Finance and also names in one of the scam from Bihar. Photocopy of the said Notification is annexed herewith and marked as "Annexure: E-2".
3. That the properties referred in the Notice of Messers Pankaj Shroff & Co, Advocates, was abuts upon a wide road of more than 25, while the properties referred in the Notification published by Income Tax Department, West Bengal, admittedly was abuts upon a much lesser wide road of just 12 road. Therefore, under the Municipal Law the Floor Area Ratio (FAR) for the properties referred in the Notice of Messers Pankaj Shroff & Co, Advocates, was entitled to get sanction for the construction of double floor area ratio, per Cottah, than the floor area ratio could have been available for the properties referred in the Notification of the Income Tax Department. Therefore according to the aforesaid Rs.3,65,400/-per cottah fixed by the Income Tax Department, as aforesaid the market value of the properties referred in the Notice of Messers Pankaj Shroff & Co, Advocates, should have been more or less Rs.7,30,000/- per cottah, thus total value of the properties arises more than Rs.73,00,000/- (Rupees Seventy three lakhs). Since the Petitioner was belongs from the same business, as such can affirm on oath that in any case the valuation of the properties referred in the Notice of Messers Pankaj Shroff & Co, Advocates was not less than Rs.35,00,000/-.
4. However, this was reported to the Petitioner that the said Mafia Sanjay Kumar Jhunjhunwala purchased aforesaid properties as referred in Notice of Messers Pankaj Shroff & Co, Advocates, against payment of more or less of Rs.45,00,000/- (Rupees forty five Lakhs) from the aforesaid Vendors, through his two Companies namely Surabhi Properties Pvt. Ltd., and Tripti Properties Ltd., both having their Registered Office at no.9/1, Lower Rawdon Street, Calcutta. The entire transaction was based on knowing fully manipulations / serious violations of the Section 269UC of Income Tax Act, and based on huge payment of black money.
5. That with intentions to violate the Income Tax Act, the said Mafia Sanjay Kumar Jhunjhunwala appointed one of his accountant: Sri Kishore Nagar of 153A, Viveka Nand Road, Calcutta as the Director in one of the aforesaid two Companies named in the Notice of Messers Pankaj Shroff & Co, Advocates. This fact also appeared from the records of the Registrar of the Companies, West Bengal Calcutta. In one of the search report given by one Advocate this was confirmed that the said Mafia Sanjay Kumar Jhunjhunwala being Director of M/S. Surabhi Properties Private Limited, being one of the Purchaser Company of the aforesaid properties, given authority letter to said Sri Kishore Nagar "to carry out necessary corrections, amendments changes, additions alterations, delitions, and such other work as may be necessary in the Memorandum of Association and Article of Association and other papers / documents filed or to be filed before the Registrar of Companies, Calcutta, West Bengal, for incorporation of above Company, in which Sanjay Kumar Jhunjhunwala was the Director. Sri Kishore Nagar further authorised to make changes, amendments, corrections, additions, delitions and alterations in the subscription clause of memorandum of Associations and Articles of Associations of above company:

2. That the aforesaid authorisation letter is sufficient proof of inter-connections between Mr. Sanjay Kumar Jhunjhunwala and Sri Kishore Nagar, as employer and employee.

1.Mr. Pranab Dutta Chowdhury, Rs.4,75,000/-

3. The Petitioner referred all aforesaid facts in his one Application Under Section 340 Criminal Procedure Code filed in one Contempt Proceedings falsely initiated by the said Mafia Sanjay Kumar Jhunjhunwala before Calcutta High Court as Matter No.3028 of 1991. With reference to affidavits filed by the Petitioners and counters filed by the said Mafia Sanjay Kumar Jhunjhunwala Petitioner prepared a List of dates, which also annexed with this Petition too. Petitioner also referred the aforesaid matter in several representations before the authority concerns, but since the said Mafia Sanjay Kumar Jhunjhunwala have very good connections with powerful politicians including Mr. Ajit Kumar Panja, who acted as Ministers of State in Union cabinet. As a result, all illegal transactions executed by the said Mafiadom were completely spared from any action under the law, which virtually strengthened the Mafia activities of the said Mafiadom. In this respect some of the representations and related other correspondence is referred below: -

4. That the Petitioner say and submit on affirmation that the Income Tax Act was violated openly in various ways in the aforesaid transactions by the said Mafia Sanjay Kumar Jhunjhunwala. Under the principle settled by the Judgment dated 13^th March 2001 in the Civil Appeal 5426 of 1997 by S.P.Bharucha, J, as His lordship then was and N. Santosh Hegde and Y. K. Sabarwal, JJ., transaction executed in favour of the Companies of the said Mafia Sanjay Kumar Jhunjhunwala were open violation of the Income Tax Act. If the respective authority could not have acted under any gratification or under any underhand dealing then either the respective properties should have been the vested with the Government of India for violation of Section 269UC of Income Tax Act, otherwise the same matter should have been the subject matter of the said Judgment, as were several other similar properties were. As such, on 11^th July 2001, Petitioner sent a representation to the Union of India, asking thereby to take appropriate steps in the matter, in accordance with the said Judgment. But, the Petitioner gets no response, from any authority in respect of the said representation. Photocopy of the said representation dated 11^th July 2001 is annexed herewith and marked as "Annexure: E-25". The purpose of insisting of action based on one property is because Sanjay Kumar Jhunjhuwala is relations and the family Members / relation of the majority Directors of Martin Burn Limited. He himself is one of the Directors in the said Company. He and his relations have purchased properties of more than of Five Hundred Crores of Rupees. Under generally practice the ratio of payment of the black money in all transactions will be more or less same and maintained in respect of all transaction for purchase or sale of the properties. The said Judgment dated 13^th March 2001 in the Civil Appeal 5426 of 1997 pronounced by S.P.Bharucha, J, as His lordship then was and N. Santosh Hegde and Y. K. Sabarwal, JJ. recorded in All India Reporter, the Petition Committee can satisfied about the submissions made by the Petitioner.

5. That till now Petitioner sent number less representations to Cabinet Secretary, Revenue Secretary, Chairman, Central Board of Direct Taxes, Central Vigilance Commission, Central Bureau of Investigation, but without any result.