JUDGMENT

Dhiraj Singh Thakur, J. - The petitioner challenges the notice under section 148 of the Income Tax Act, 1961 ('the Act') dated 31st Mach 2021 for the assessment year 2014-15 seeking to reopen the assessment for the said year on the ground that the Assessing Offcer had reasons to believe that income chargeable to tax for the assessment year 2014-15 had escaped assessment within the meaning of section 147 of the Act. The petitioner also challenges the order dated 8th February 2022 rejecting the objections of the petitioner to the validity of the notice under section 148 of the Act.

2. Briefy stated the material facts are as under :

2.1 The petitioner is stated to be engaged in the business of stock broking services as well as Undertaking Stock Trades (Pro-Trade) on BSE and NSE in derivative and cash segments which constitutes its business activity.

2.2 It is stated that the resultant Proft/Loss arising from such Pro-trade activity of the petitioner is offered to tax as 'business income/loss' in its return of income. It is stated that delivery based transactions in the nature of purchase and sales of equity shares in the cash segment, as also the sales and purchase of shares on I