JUDGEMENT :

N.R. BORKAR, J.

1. This petition takes an exception to the notice dated 30.03.2021 issued by respondent No.2 under section 148 of the Income Tax Act, 1961 (for short “the Act”) seeking to reopen the assessment for Assessment Year (A.Y.) 2014 -15 and the order on objections dated 13.12.2021 passed by the respondent No.1.

2. The petitioner is a company incorporated under the Companies Act and is engaged in the business of hotels and power generation from windmills.

3. The petitioner fled its original return of income in terms of section 139 of the Act for A.Y. 2014-2015 on 29.11.2014 declaring total income of Rs.26,79,01,280/- after claiming deduction under section 80-IA of the Act amounting to Rs.5,42,49,584/-.

4. Subsequently, the petitioner fled a revised return on 25.03.2016 declaring total income of Rs.16,31,11,500/- after claiming deduction under section 80-IA of the Act amounting to Rs.16,00,18,236/-.

5. The petitioner’s return was selected for scrutiny assessment. The notice under section 142(1) of the Act calling upon the petitioner to file various details / documents to complete assessment was issued. Specific details pertaining to deduction claimed under section 80-I