JUDGMENT :

K.R. SHRIRAM, J.

1. Rule. Rule made returnable forthwith as pleadings are completed.

Petitioner is registered with the Reserve Bank of India (RBI) as Non- Banking Finance Company and is classified as an Asset Finance Company.

On 28th November 2016, petitioner filed its return of income for A.Y.-2016- 2017 declaring a total income of Rs.44,92,46,370/-. Later petitioner filed revised return of income on 28th March 2018 declaring a total income of Rs.50,67,32,580/-.

2. The return of income was selected for scrutiny and a notice dated 5th September 2018 under Section 143(2) of the Income Tax Act 1961 (the Act) was issued. This was followed by notice dated 5th December 2018 under Section 142(1) of the Act. Petitioner responded by its letter dated 6th December 2018 and submitted the transaction wise summary on expenditure on software consumables. Respondent no.1 passed an assessment order dated 23rd December 2018 under Section 143(3) of the Act without making any adjustments to the total income as reported by petitioner in its revised return of income.

3. Almost three years later, petitioner received notice dated 25th June 2021 under Section 148 of the Act, stating that there was re