JUDGMENT :

KAMAL KHATA, J.

1. By this petition, the petitioner challenges the notice dated 31st March 2021, issued under section 148 of the Income Tax Act, 1961 (‘the Act’) by respondent No.1 seeking to reopen the assessment, on the basis of ‘his reason to believe’ that income chargeable to tax for the assessment year 2016-17 had escaped assessment within the meaning of section 147 of the Act; and the order dated 11th March, 2022 disposing of the objections raised by the Petitioner inter alia on the ground that the respondent failed to consider the contentions raised did not conduct any further enquiry.

FACTS :

2. The Petitioner is engaged in the business of trading in electronic appliances and has filed its returns on a regular basis and even for A.Y.2013-14. The respondent No. 1 by its order under section 143(3) of the Act dated 14th March 2016 accepted the returned income of the Petitioner for A.Y. 2013-14 after considering the submissions filed by the Petitioner. It filed its return of income under section 139(1) of the Act on 13.10.2016 for A.Y. 2016-17 declaring a total income of Rs. 2,85,63,750/-. The Petitioner’s books of accounts were audited, and the auditor uploaded the audi