JUDGMENT :

K.R. Shriram, J.

1. The petitioner has impugned notice dated 30.03.2019 received under Section 148 of the Income Tax Act, 1961 (the Act). After petition was filed, an order dated 30.01.2021 u/s 92-CA(3) of the Act came to be passed. Petition was, therefore, amended pursuant to the liberty granted by this Court on 20.2.2021 by which respondent no.2 re-initiated transfer pricing proceedings which were already concluded pursuant to re-opening of assessment by respondent no.1.

2. Mr. Sridharan submitted that if the Court is going to set aside notice issued under Section 148 of the Act then consequence thereof will be to set aside all revised orders passed by respondent no.2 u/s 92-CA(3). He submitted that there is enough material to set aside notice under Section 148 of the Act and at the same time, if notice u/s 148 goes, there will be a cascading effect and all other orders will also go.

3. Petitioner filed its return of income for the Assessment Year 2012- 2013 on 29.11.2012 declaring total income of Rs.9,90,48,280/-. Return was processed u/s 143(1) of the Act on 19.02.2014 accepting the return income of Rs.9,90,48,280/-. Petitioner’s case was thereafter taken up for regular