JUDGMENT :

(Prayer: Writ Petition filed under Article 226 of the Constitution of India praying to issue a Writ of Certiorari, calling of records of the respondent herein pertaining to notice dated 10.03.2016 for AY 2009-2010 and consequential communication No.Misc/Corp.Cir 6(2)/2014-15 dated 26.9.2016, issued by the respondent and quash the same.)

1. The reopening of assessment made under Section 147/148 of the Income Tax Act, 1961 [hereinafter referred to as the ‘Act’] is under challenge in the present writ petition.

2. The petitioner is a company incorporated under the Companies Act, 1956. The petitioner has been in the business of manufacturing of automobile parts and is a leading supplier to Companies such as Hyundai for over fifteen years. On 28.09.2009, the petitioner filed its return for the Assessment Year 2009-10. Notice under Section 142(1) of the Act was issued on 14.11.2011 along with the questionnaire. The petitioner furnished all the material information’s and disclosed such information truly and fully. The case was referred to the Transfer Pricing Officer on 06.12