JUDGMENT

Akil Kureshi, J. - The petitioner has challenged a notice of reopening of assessment dated 29th March, 2018 under which the respondent no.1 Assessing Officer has reopened the petitioner''s assessment for A.Y. 2011-12. In order to issue the notice, the Assessing Officer had recorded following reasons :

"1. In this case return of income for A.Y. 2011-12 has been filed on 25.3.2013 declaring total income at Rs. NIL/. The assessee is a builder and developer.

2. A detailed investigation report has been forwarded by Directorate of Investigation, Unit1( 2), Ahmedabad regarding survey action conducted on M/s. Mudra Finvest (Guj) Ltd. On 8.12.2016. The entity is involved in the jewellery business.

3. Four hard disk which contain digital data were impounded from the premises, 6 ground floor, revdi bazaar, Ahmedabad during survey. On examination of these disks it is seen that M/s. MUDRA REAL ESTATE PRIVATE LTD is a group entity who has constructed and developed project "4D SQUARE" in Ahemdabad - Gandhi Nagar road.

3.1 The tally data from the disk, contained ledgers of various parties cash book, trial balance, P/I account and balance sheet of M/s. Mudra Real Estate Private Ltd. For F.Y