ORDER :

J.B. PARDIWALA, J.

1. By this writ application under Article 226 of the Constitution of India, the writ applicant (assessee) has prayed for the following relief’s;

“(A) quash and set aside the impugned notice at Annexure-A to this petition;

(B) pending the admission, hearing and final disposal of this petition, to stay the implementation and operation of the notice at Annexure-A to this petition and stay the further proceedings for the Assessment Year 2012-13;

(C) any other and further relief deemed just and proper be granted in the interest of justice;

(D) to provide for the cost of this petition.”

2. The present litigation is one of reopening of the assessment for the A.Y. 2012-13 in a case where the original return was taken in scrutiny and an order of assessment under Section 143(3) of the Act was passed. This is a case in which the reopening is beyond the period of four years.

3. The case of the writ applicant may be summarized as under;

“2.2. The writ applicant, during the Financial Year 2011-12 relevant to Assessment Year 2012-13 (i.e. the year under consideration), was engaged in the business of manufacturing and trading of agro processing as well as maize processing. The w