JUDGMENT

K.R. Shriram, J. - Petitioner is impugning a notice no.ITBA/AST/S/148/2018- 19/1015547197(1) dated 30th March 2019 issued by respondent no.1 under Section 148 of the Income Tax Act, 1961 (the Act) for the Assessment Year 2012-2013 and the subsequent order [Letter No.ITBA/AST/F/17/2019- 20/1017795202(1)] passed on 5th September 2019 rejecting the objections raised by petitioner.

2. By a notice dated 30th March 2019 issued under Section 148 of the Act, respondent no.1 informed Niraj Realtors and Shares Pvt. Ltd. (Niraj Realtors) that he has reasons to believe that Niraj Realtors' income chargeable to tax for the Assessment Year 2012-2013 has escaped assessment within the meaning of Section 147 of the Act. Niraj Realtors was called upon to deliver a return in the prescribed form for the said Assessment Year. The reasons required to be given for re-opening under Section 148 of the Act was provided by respondent no.1 to Niraj Realtors almost six weeks later by a communication dated 17th May 2019. The reasons, opens with admission of the fact that Niraj Realtors had merged in and was known as Alok Knit Exports Pvt. Ltd. and had e-filed its return of income tax for the Assessment Y