JUDGMENT :

(Bhargav D. Karia, J.)

1. Heard learned advocate Mr.B.S.Soparkar for the petitioner and learned advocate Mr.Varun K. Patel with learned advocate Mr.Dev Patel for the respondent.

2. Rule, returnable forthwith. Learned advocate Mr.Dev Patel waives service of notice of rule for and on behalf of the respondent.

3. By this petition under Article 226 of the Constitution of India, the petitioner has prayed for quashing and setting aside the order dated 20th March, 2020 passed under Section 264 of the Income Tax Act, 1961 (for short ‘the Act’).

4. The brief facts of the case are as under :

4.1. The petitioner is a limited Company incorporated under the provisions of the Companies Act, 1956 and is engaged in business of weaving, manufacturing and finishing of textiles. The petitioner is also engaged in business of manufacturing and dealing in Denim and other textile activities.

4.2. For the Assessment Year 2015-16, the petitioner filed return of income on 31.10.2015 declaring total loss of Rs.8,54,09,913/- including the Interest Subsidy of Rs.10,83,16,142/- received by the petitioner under Technology Upgradation Fund Scheme (TUFS) for Textile and Jute Industries, State Interest subsid