JUDGMENT :

Bhargav D. Karia, J.

1. Rule returnable forthwith.

2. Ms.Maithili Mehta, learned Senior Standing Counsel waives service of notice of Rule on behalf of respondent.

3. Having regard to the controversy in narrow compass, with the consent of learned advocates for the parties, the matter is taken up for hearing.

4. By this petition under Article 226 of the Constitution of India, the petitioner has challenged the notice issued under Section 148 of the Income-Tax Act, 1961 (for short ‘the Act’) dated 21.3.2021 for reopening of the Assessment Year 2017- 18.

5. The petitioner, who is an importer and refiners of edible oil in India, filed original return of income for Assessment Year 2017-18 on 22.11.2017 which was revised on 26.11.2018, declaring total income of Rs.54,94,84,050/- under the normal provisions and book profit of Rs.345,20,74,045/- under MAT provisions of the Act.

5.1 The case of the petitioner was selected for scrutiny and detailed notice under Section 142(1) of the Act dated 5.7.2019 was issued, requiring the petitioner to furnish various details with respect to break-up of ‘any other amount allowable as deduction’ claimed in Schedule BP of return, wherein notional guaran