ORDER :

ILESH J. VORA, J.

1. By filing this writ application under Article 226 of the Constitution of India, the writ applicant seeks to challenge the impugned Notice issued under Section 148 of the Income Tax Act, 1961 (hereinafter referred to as the Act for short) dated 01.03.2008 for the A.Y. 2012-13, whereby, the assessment is sought to be reopened in exercise of the powers under Section 147 of the Act, 1961.

2. The brief facts can be summarized as under:

2.1 The assessee company is engaged in the manufacuring of pharmaceutical intermediates. The assessee filed its e-return of income on 27.09.2012 declaring total income at Rs.2,02,52,860/-. The return was processed under Section 143 (1) of the Act. The case was selected for scrutiny assessment and under Section 143 (2) of the Act, the notice was issued on 06.08.2013. The notice under Section 142 (1) of the Act along with questionnaire was issued on 17.10.2013 and 30.10.2014 and in response to the notices, the assessee company submitted its details. After perusing the details furnished by the assessee, the assessing officer raised the issues i.e. (1) Disallowance of cash payment under Section 40A (3) of the Act, (2) Employee's contr