JUDGMENT :

K.R.Shriram, J.

1. Rule. Rule made returnable forthwith. By consent of parties taken up for final hearing.

2. Petitioner, for Assessment Year 2016-17, filed return of income on 29th November 2016 declaring total income of Rs.4860,25,58,663/-. The assessment was completed under Section 143(3) of the Income Tax Act, 1961 (“the Act”) assessing the total income Rs.5163,85,46,552/-.

3. Petitioner received a notice dated 27th March 2021 under Section 148 of the Act stating that there were reasons to believe Petitioner’s income chargeable to tax for AY 2016-17 has escaped assessment within the meaning of Section 147 of the Act. By a communication dated 17th February 2021, Petitioner was provided the reasons for reopening. The same reads as under:

“1. The assessee Bajaj Auto Ltd., having PAN: AADCB2923M is assessed to tax in this charge. In this case return of income was filed on 29.11.2016 declaring total income Rs.48,60,25,58,663/-. The assessment was completed u/s.143(3) of the IT Act assessing the total taxable income of Rs.51,63,85,46,552/-.

2. It is found from the return and