JUDGMENT :

SONIA GOKANI, J.

1. The petitioner is a limited company which had filed the original return of income for the assessment year 2018-19 on 30.11.2018 declaring the total income at Rs. 59,03,19,030/-. The assessee filed the revised return of income declaring the total income of Rs. 57,46,07,670/-. It is a company engaged in the business of manufacturing and sale of pharmaceutical products.

2. The case of the petitioner was selected for the scrutiny under CASS and notice under Section 143(2) of the Income Tax Act, 1961 (hereinafter referred to as ‘the Act’) was issued to the petitioner on 22.09.2019 and thereafter, notice under Section 142(1) of the Act dated 20.09.2021 was issued.

2.1. The petitioner submitted its response on 04.10.2019 and 24.09.2021. The part information were by the petitioner tendered on 24.09.2021 and sought a short adjournment to furnish the remaining details as it was allowed only four days to submit such a response.

2.2. Since one of the reasons for selection of the case under scrutiny was international transactions – T.P. Risk Parameters as per para