JUDGMENT

(Prayer: Writ Petition filed under Article 226 of the Constitution of India praying to issue a Writ of Certiorarified Mandamus, calling for the entire records of the Respondent contained in impugned Notice No.ITBA/AST/F/17/2018- 19/1015381247(1) dated 21.03.2019 issued under Section 148 of the Income Tax Act, 1961 [hereinafter referred to as the Act] for PAN:AAACE2125M for Assessment Year 2012-13 along with all consequential orders issued thereto, including the order dated 31.07.2019, dismissing the objections of the petitioner for re-opening the assessment under Section 147 of the Act, and to quash the same, as arbitrary, unjust and illegal, and to consequently forbear the respondent or any of its superiors, subordinates, agents or any other person claiming under or above the respondent, form in any manner re-assessing the petitioner’s income for the assessment year 2012-13 under Section 147 of the Income Tax Act, 1961.)

1. The petitioner is a company assessed to income tax on the file of the sole respondent in terms of the provisions of Income Tax Act, 1961 (in short ‘Act’). In respect of assessment year (AY) 2012-13 a return of income had been filed disclosing income both