JUDGMENT :

Bhargav D. Karia, J.

1. Rule. Mr. Nikunt Raval, learned senior standing counsel waives service of notice of rule on behalf of the respondent.

2. Having regard to the controversy involved in the present case which lies in a very narrow compass, with the consent of the learned advocates for the respective parties, the matter is taken up for final hearing.

3. The petitioner has challenged a notice dated 28.03.2018 for reopening of assessment for the assessment year 2011-2012 issued by the respondent under section 148 of the Income-tax Act, 1961 ("the Act" for short).

4. Brief facts of the case are as under:

4.1 The petitioner is an authorised dealer of foreign exchange. For the Assessment Year (for short "A.Y.") 2011-2012, the petitioner submitted e-return of income declaring total income of Rs.4,37,543. During the course of the assessment proceedings, the petitioner submitted audit report and financial statement wherein profit and loss account under the caption "Expenditure", there was a debit of Rs. 36,53,147 under the head "Administrative and other Expenses", the break-up