S. Ravindra Bhat, J.

In the present writ petition, the validity of an order under Section 142(2A) of the Income Tax Act (hereafter referred to as "Act") issued by the Assessing Officer (hereafter referred to as "AO") on behalf of the respondent (hereafter referred to as "Revenue") has been challenged. The petitioner, a Public Sector Undertaking (PSU) and hereafter called "NPCC", urges various grounds, including non-application of mind and unfairness by the AO.

2. The NPCC filed its return for Assessment Year (AY) 2016-17 on 16.10.2016 declaring a total income of Rs. 18,02,20,380/-. Later, it revised its return on 29.03.2018 to reflect the correct TDS credit available based upon the AS-22 receipts. The return was selected for scrutiny and the notice was issued on 07.09.2018 by the Revenue. The NPCC was asked to produce the documents it relied upon in respect of its returns. It submitted - on 20.09.2018 computation of income and audit financials in respect of return of income. Another notice calling for information was issued by the Revenue on 29.09.2018. The NPCC uploade