JUDGMENT :

Aravind Kumar, J.

1. By way of this petition under Article 226 of the Constitution of India, petitioner has challenged the legality and validity of the impugned notice dated 29.03.2018 at Annexure-A and has sought for quashing of the same.

2. The case of the petitioner is that it is a Company registered under the provisions of the Companies Act and most of the shareholders are citizens of India and respondent being authority under Article 12 of the Constitution of India, it has invoked extraordinary jurisdiction of this Court.

3. The case of the petitioner is that it has filed its original return of income for the A.Y. 2011-12 on 27.09.2011 declaring total income at Rs.11,99,50,930/- and the revised return of income was filed on 27.09.2012 declaring total income at Rs.12,02,45,130/-. The authority has selected petitioner’s case for scrutiny and passed an assessment order in exercise of power under Section 143(3) of the Income Tax Act, 1961 (for short the “Act”) dated 29.03.2014 assessing the income at Rs.13,64,40,534/-. Thereafter, the authority issued notice to petitioner under Section 148 of the Income Tax Act on 30.03.2016 and an order came to be passed thereafter under Section 143(3) read with Section 148 of the Act.

3.1. It is the case of the petitioner that later on, respondent issued impugned notice under Section 148 of the Tax Act on 29.03.2018 for re-opening the assessment for the A.Y 2011-12 and also supplied the reasons for re-opening vide letter dated 04.07.2018. The petitioner - assessee raised multiple contentions by way of objections on merit as well and requested to drop the reassessment proceedings vide its communication dated 17.10.2018. Later on, an order came to be passed on 25.10.2018 rejecting the objections raised by petitioner and according to petitioner, impugned notice issued under Section 148 of the Act as well as order disposing of objections, are bad in law, illegal and having no other efficacious remedy, has invoked extraordinary jurisdiction of this Court by way of present petition.

4. On the basis of unilateral submission of learned Senior Advocate Mr. Saurabh N. Soparkar, who appeared for the petitioner, the co-ordinate Bench of this Court vide order dated 30.10.2018 was pleased to issue notice and by way of ad-interim order, impugned notice came to be stayed. It is in this background, petition has come up for consideration before us and pursuant to the request having been made, we took up the matter for final disposal since the pleadings are complete.

5. Mr. S.N. Soparkar, learned Senior Advocate appearing for the petitioner has raised multiple contentions and by referring to various documents attached to the petition compilation, has submitted that the authority while considering the objections has failed to deal with the specific objections which have been raised by petitioner and in a stereo type manner, mechanically, without applying mind, disposed of same and as such, it is under challenge contending it is suffering from vice of non-application of mind and there appears to be no subjective satisfaction by the authority who is under an obligation to consider the same. It has been contended that impugned action in any case is beyond the period of four years and as such, according to the provisions contained under the Act, re-opening of the assessment is impermissible and as such, the authority has acted without jurisdiction. Mr. Soparkar, learned Senior Advocate has further submitted that reasons which are assigned for issuance of notice under Section 148 of the Act of re-opening of assessment are not germane to law and rather same are factually incorrect. By drawing our attention to specific detailed objections raised by petitioner dated 17.10.2018, Mr. Soparkar, learned Senior Advocate has submitted that specific details have been provided along with necessary documents, the authority in a copy-paste manner has just narrated the reasons and without applying mind has discarded the obje