JUDGMENT :

SONIA GOKANI, J.

1. The petitioner is before this Court under Article 226 of the Constitution of India seeking to challenge the action of the respondent-authority in the following factual background:

1.1. The petitioner is in the business of real estate development and has filed its return of income on 13.09.2018 offering Rs. 64,68,084/- as tax on income.

1.2. Its case was selected for the scrutiny and a notice dated 22.09.2019 under Section 143(2) of the Income Tax Act, 1961 (hereinafter referred to as ‘the Act’) read with Rule 12E of the Income Tax Rules, 1962 (hereinafter referred to as ‘the Rules’) was issued. The respondent, on 14.10.2020 issued a communication to the petitioner that the assessment shall be completed in accordance with the Faceless Assessment Scheme, 2019.

1.3. On 07.11.2020, notice in the form of questionnaire came to be issued under Section 142(1) of the Act requesting the petitioner to submit various details in the annexure appended to the notice. A further reminder was addressed to the petitioner on 18.12.2020 by giving reference of the notice dated 17.11.2020. The petitioner, on 25.12.2020, attempted to send all the details which were sought. Furthe