JUDGMENT

Dhiraj Singh Thakur, J. - The petitioner questions the legality of a Notice dated 30th March 2021 issued under section 148 of the Income Tax Act, 1961 ('the Act') seeking to reopen the petitioner's assessment for the assessment year 2015-16. The petitioner also challenges the order dated 21st July 2022 passed by the respondent No.1, whereby the objections to the reopening of the assessment have been disposed of.

2. Briefy stated the material facts are as under :

2.1 The petitioner fled a return of income for the assessment year 2015-16. The case was subsequently selected by Computer Assisted Scrutiny Selection (CASS) for scrutiny assessment. Notices were issued under section 143(2) of the Act on 17th March 2016 and subsequently under section 142(1), dated 23rd January 2017. Necessary information and details were fled pursuant to such notices including the petitioner's claim for deduction under section 35(2AB) of the Act. Finally, an order of assessment dated 13th June 2017 was passed under section 143(3) of the Act assessing the total income at Rs.8,48,00,190/-, by disallowing Rs.32,70,724/- being excess deduction claimed under section 35(2AB) of the Act. The disallowance was