JUDGMENT :

DHIRAJ SINGH THAKUR, J.

1. The present petition is fled, inter-alia, challenging the notice, dated 26th March 2021, issued u/s. 148 of the Income Tax Act, 1961 (‘the Act’), whereby the reassessment proceedings are sought to be initiated against the petitioner for the assessment year 2015-16.

2. Briefly stated the material facts are as under:

(a) The petitioner is a company engaged in the business of infrastructure development and running a Container Freight Station. Return of income for the assessment year 2015-16 was fled on 30th September 2015 and declared book profit u/s. 115-JB of the Act of Rs. 8,72,54,012/-. The petitioner in its return claimed a deduction of Rs. 10,24,27,306/- u/s. 80-IA(4) of the Act. The case of the petitioner was selected for scrutiny for purposes of verification of claim as regards deduction under Chapter VI-A of the Act.

(b) A notice u/s. 143(2) of the Act dated 27th July 2016 was issued and subsequently a notice u/s. 142(1) dated 19th January 2017 was issued.

(c) Reply dated 3rd May 2017 is stated to have been fled along with acknowledgment of fling revised Form 10-CCB for A.Y. 2015-16 dated 27th April 2017 and un-audited accounts for infrastructu