JUDGMENT :

Jitendra Jain, J.

1. Heard learned counsel for the parties.

2. Rule. Rule made returnable immediately at the request and with the consent of the learned counsel for the parties.

3. This petition challenges a notice under section 148 of the Income -tax Act, 1961 (the Act) dated 30 March 2021 for the assessment year 2013-14.

4. The petitioner filed its return of income on 30 November 2013. The said return was selected for scrutiny assessment and the petitioner in the course of the assessment proceedings, pursuant to various queries raised by the assessing officer, filed various details, including the details on which the impugned proceedings are initiated.

5. On 22 February 2017, an assessment order under section 143(3) of the Act was passed disallowing certain percentage of expenses on samples given to doctors on the ground that same constitutes sale promotion expenses incurred on the doctor. The said order is a subject matter of an appeal. We are informed that the said appeal is pending as of today.

6. On 30 March 2021, impugned notice under section 148 of the Act was issued for reopening the case calling upon the Petitioner to file its return of income since the assessing offi