JUDGMENT :

K.R. Shriram, J.

1. Petitioner is an individual who had filed on 23rd July 2014 his original Return of income (ROI) tax for A.Y. 2014-15 declaring total income of Rs.1,89,69,048/-. Subsequently, on 23rd July 2015, petitioner filed revised ROI at Rs.2,54,08,853/-. The ROI was processed under Section 143(1) of the Income Tax Act, 1961 (the said Act).

2. Subsequently, petitioner received a notice dated 31st March 2021 under Section 148 of the Act stating that the respondent no.2 has reasons to believe that petitioner’s income for A.Y. 2014-15 chargeable to tax has escaped assessment within the meaning of Section 147 of the Act. Petitioner was later provided a copy of the approval under Section 151 of the Act alongwith reasons recorded for such belief.

3. Petitioner filed its objections and the objections came to be rejected by an order dated 21st January 2022. The notice dated 31st March 2021 and the order dated 21st January 2022 are impugned in this petition.

4. Mr. Pardiwalla submitted that even though the notice under Section 148 of the Act has been issued more than four years after the expiry of the relevant assessment year, the assessment not having been completed under Sec