JUDGMENT :

KAMAL KHATA, J.

1. The Petitioner challenges the notice under section 148 of the Income-tax Act, 1961 (‘Act’) dated 27th March 2021 for the Assessment Year (‘AY’) 2015-16 issued by Respondent No. 1 for seeking to reopen the said year’s assessment on the ground that income chargeable to tax had escaped assessment as provided in section 147 of the Act. The Petitioner also challenges the order dated 2nd December 2021, rejecting the objections to the proposed action of reopening.

2. Petitioner is a Government Corporation engaged in the business of generation of electricity from atomic energy. In its return of income filed on 30th September 2015, it declared total loss of Rs. 240,87,30,919 under normal provisions and Book Profit at Rs. 2911,17,90,229/- under section (‘u/s’) 115JB of the Act. Its case was selected for scrutiny and assessment u/s 143(3).

3. By a notice u/s 142(1) dated 28th August 2017 the following details were sought from the Petitioner:

(i) A copy of the Annual report, tax audit report, e-return, computation of income, working of Book Profits with requisite report, report in form 3 CEB if any. All the above should be accompanied by all the schedules and annexure