SANJIV KHANNA, J.

1. We have heard counsel for the parties, and with their consent taken the writ petition for final hearing. We have also perused the departmental records which has been produced by the counsel for the respondents.

2. The petitioner, Scan Holding (P) Ltd., has challenged initiation of proceedings under Section 147 read with 148 of the Income Tax Act, 1961 (Act, for short) vide notice dated 31.03.2015 for the Assessment Year (AY) 2008-09.

3. It is accepted and admitted that the original return filed by the petitioner for the AY 2008-09 was not subjected to scrutiny assessment and was processed under Section 143 (1) of the Act. Thus, this is not a case of change of opinion.

4. Reasons to believe, for initiation of proceedings for the AY 2008-09, read :-

"Income Tax Return for the A.Y. 2008•09 was filed by the assessee on 28.09.2008 declaring income of 3,64,26,780/-.

1. Commission on sales received:

In the case, information in the form of complaint of Tax evasion dated 10.12.2014 &12.03.2015 has been received in this office. As per the information received, the company is stated to be involved in money laundering. The company has tried to convert its black money in