JUDGMENT :

BELA M. TRIVEDI, J.

1. The vexed issue as to whether the Assessing Officer could have assumed the jurisdiction under section 147/148 of the Income Tax Act, 1961 (hereinafter referred to as ‘the said Act’) for reopening the assessment on the basis of the subsequent reliable and creditworthy information received by him from the investigating wings, unearthing the bogus transactions or accommodation entries involving the assessee, has cropped up in this petition.

2. The petitioner company by way of present petition filed under Article 226 of the Constitution of India has challenged the action of the respondent in reopening of the assessment for the A.Y. 2012-13 under section 147 of the Income Tax Act, 1961 vide the notice dated 27.03.2019 issued under section 148 of the said Act thereof, as also the order dated 13.12.2019 passed by the respondent rejecting the objections filed by the petitioner against the reopening of the assessment.

3. The conspectus of the case as emerging from the record is that the petitioner had filed its return of income along with the audit report for the A.Y. 2012-13 on 31.03.2013. The assessment order in that regard was passed by the then Assessing Of