JUDGMENT

Md. Nizamuddin, J. - The Court:

1. Heard learned Counsel appearing for the parties.

2. In this Writ Petition petitioner has challenged the impugned notice dated 26th March, 2021 under Section 148 and final assessment order dated 31st March, 2022, under Section 147/143 (3) of the Income Tax Act, 1961, relating to assessment year 2017-18 raising a demand of Rs. 8,57,19,806/-.

3. Peculiar facts involved in this case as appears from record annexed to the Writ Petitioner by the petitioner itself is that on 26th October, 2021 petitioner received the impugned notice under Section 148 of the Act by which it was asked to file a return in the prescribed form for the relevant assessment year as appears at Page 38 of the Writ Petition and in response to the said notice petitioner filed a return on 9th October, 2021. Thereafter, as appears from Page 45 of the Writ Petition that on 22nd October, 2021 petitioner's authorised representative one Murarka & Associates asked the Assessing Officer for furnishing of the recorded reason for issuance of the aforesaid notice. It appears at Page 48 of the Writ Petition that the respondent Assessing Officer concerned furnished recorded reason to the pe