M.R. Shah, J.

1. By way of this petition under Article 226 of the Constitution of India, the petitioner - assessee has prayed for appropriate writ, order and/or direction to quash and set aside the impugned notice issued under section 148 of the Income-Tax Act, 1961 dated 27/3/2014 for the A.Y. 2007-2008. Thus, the petitioner has challenged reopening proceedings of the assessment for A.Y. 2007-2008 initiated in exercise of powers under section 147 of the Income-tax Act. Facts leading to the present Special Civil Application in nutshell are as under:-

1.1 That the petitioner is a Company engaged in I.T. Enabled Services and Software Development. The petitioner filed its return of income for A.Y. 2007-2008 on 21/10/2007 declaring total income at Rs. 5,52,52,210/-.

1.2 That the case was selected for scrutiny and notices under section 142(1) and under section 143(2) of the Income-tax Act were issued and served upon the petitioner - assessee. It appears that in the notice dated 12/11/2010, specific query regarding Software License Fees was raised.

1.3 That thereafter the Assessi