JUDGMENT :

DHIRAJ SINGH THAKUR, J.

1. In this petition, the petitioner challenges the notice, dated 30th March 2021 issued by respondent No. 1 under section 148 of the Income Tax Act, 1961 (‘the Act’) proposing to reopen the assessment for the assessment year 2016-17 on the ground that the income exigible to tax for the said assessment year has escaped assessment. The petitioner also challenges the order dated 25th February 2022, passed by respondent No. 4, whereby, the objections raised by the petitioner for the reopening the assessment have been disposed of.

2. Briefly stated the material facts are as under:

(a) The petitioner is a company engaged inter-alia in the business of FM Radio Broadcasting. Return of income for the assessment year 2016-17 was fled under section 139(1) of the Act on 16th October 2016 declaring a total loss of Rs. 7,88,83,872/-. By virtue of notice, dated 26th July 2017 issued under section 143(2) of the Act, as a part of the limited scrutiny among others identified the issue related to intangible assets for examination.

(b) In response thereto, the petitioner claims that it fled the relevant details, supported by documents explaining as to how the amounts paya