JUDGMENT :

ASHOKKUMAR C. JOSHI, J.

1. This petition, under Articles 226 and 227 of the Constitution of India, is filed by petitioner - Geetaben Dineshchandra Gupta challenging the notice dated 27.03.2019, issued under section 148 of the Income Tax Act, 1961 (hereinafter referred to as ‘the Act’) proposing to reopen the assessment of the petitioner for the Assessment Year 2012-13.

2. The facts of the case in nutshell are that the petitioner as individual filed Return of Income (Rol) for the year 2012-13, which was thoroughly processed by the respondent and subsequently, scrutiny assessment under Section 143(3) of the Act was also framed. The petitioner filed Rol at Rs.1,42,694/- on 28.09.2012. On 13.08.2013, notice under Section 143(2) of the Act came to be issued to provide certain documents. On 22.07.2014 and subsequently, on 05.08.2014, the petitioner received notices under section 142(1) of the Act, to which, the petitioner filed detailed reply on 04.09.2014. The respondent passed Assessment Order under section 143(3) of the Act on 14.10.2014. It is contended that despite the petiti