JUDGMENT :

K.R. Shriram, J.

1. By consent, Petition taken up for hearing at the stage of admission itself. Therefore, Rule. Rule made returnable forthwith.

2. Petitioner is in the business of shares and stock broking. Petitioner is challenging the action of Respondent No.1 of issuing notice dated 31st March 2021 under Section 148 of the Income Tax Act, 1961 (“the Act”) seeking to reassess Petitioner’s income for Assessment Year (“AY”) 2015-16. Petitioner is also challenging an order dated 26th February 2022 passed by Respondent No.2 rejecting Petitioner’s objections to the issuance of notice under Section 148 of the Act.

3. Petitioner had filed on 29th September 2015, its return of income for AY 2015-16. Petitioner declared income of 'Nil'. An assessment under Section 143(3) of the Act was made and an assessment order dated 14th December 2017 came to be passed determining Petitioner’s total income at Rs.58,96,900/-.

4. Petitioner thereafter received the impugned notice dated 31st March 2021. Petitioner filed its objections vide letter dated 6th January 2021. Petitioner’s objections came to be rejected by the impugned order dated 25th March 2022.

5. Since in this case, the impugned notice