JUDGMENT :

K.R. SHRIRAM, J.

1. Petitioner is impugning a notice dated 2nd August 2019 issued under Section 148 of the Income Tax Act 1961 (the Act) for A.Y. 2013-2014 and for quashing an order dated 5th December 2019 passed by respondent no. 1 disposing of the objections filed by petitioner against initiation of reassessment proceedings for A.Y. 2013-2014.

2. For A.Y. 2013-2014 petitioner filed return of income on 30th November 2013 declaring total income at loss of Rs. 4,60,12,34,048/- under normal provisions and Rs. 273 crores under Section 115JB of the Act. Revised return of income was also filed declaring income as shown in original return of income. The assessment was completed on 30th December 2016 under Section 143(3) of the Act determining total income at Rs. 24,76,63,28,847/- under normal provisions and Rs. 13,96,21,60,821/- under Section 115Jb of the Act.

3. Thereafter, petitioner received notice dated 2nd August 2019 under Section 148 of the Act saying that there are reasons to believe that petitioner’s income chargeable to tax for A.Y.-2013-2014 has escaped assessment within the meaning of Section 147 of the Act. Since the notice has been issued after the expiry of 4 years