ORDER :

ILESH J. VORA, J.

1. By filing this writ application under Article 226, the writ applicant seeks to challenge the notice dated 31.03.2019 issued by the respondent under Section 148 of the Income Tax Act, 1961 (‘the act’ for short) seeking to reopen the applicant’s income assessment for the A.Y 201213.

2. The brief facts can be summarized as under:

2.1 The writ applicant – assessee Company filed its return of Income for the A.Y. 201213 on 28.09.2012 declaring total income at Rs. 6,58,710/and an assessment under Section 143(3) of the Act was completed on 04.06.2014.

2.2 The Assessing Officer has reopened the assessment under Section 147 by issuing impugned notice dated 31.03.2019 under Section 148 of the Act.

2.3 At the request, the reasons recorded have been furnished to the assessee on 09.05.2019, which reads as under :

“2. Since you have filed return of income in response to notice u/s.148 of the incometax act, therefore reason for reopening is provided as under.

“The assessee company filed its return of income for the A.Y. 201213 on28/09/212 declaring total income at Rs.6,58,710/. The assessee was engaged in the business of trading in rough and polished diamonds. The assessment U