AKIL KURESHI, J.

The petitioner has challenged a notice dated 12.03.2015 issued by the respondent Assessing Officer to reopen the petitioner's assessment for the assessment year 2010-11, which was framed after scrutiny.

2. Brief facts are as under.

3. The petitioner is a company registered under the Companies Act and is engaged in manufacturing and sale of pharmaceutical drugs. For the assessment year 2010-11, the petitioner had filed return of income on 15.10.2010 declaring total income of Rs. 25.17 crores (rounded off) and book profit under section 115JB of the Act at Rs. 96.56 crores (rounded off). The case of the company was taken in scrutiny by the Assessing Officer. One of the major claims of the petitioner was of deduction under section 80IC of the Income Tax Act, 1961 (‘the Act’ for short) relating to its unit eligible for exemption situated in Himachal Pradesh. Such claim was examined by the Assessing Officer in the scrutiny assessment. Many other issues came up for consideration. Eventually, the Assessing Officer passed the order of assessment on 28.03.2014, assessing the petitioner's total income at Rs. 65.87 crores (rounded off).

4. In order to reopen such assessm