JUDGMENT :

This Writ Appeal is filed challenging the order of this Court dated 26.09.2023 passed by the learned Single Judge in W.P.No.8014 of 2022, dismissing the Writ Petition filed by the Appellant herein viz., assessee.

2. The appellant has filed the above said writ petition challenging the impugned notice issued by the first respondent under Section 148 of the Income Tax Act, 1961 (herein after referred to as 'the Act') dated 30.03.2021 for the Assessment Year 2014-15 along with the impugned order disposing off the objections of the Appellant/petitioner dated 15.02.2022 for the Assessment Year 2014-15 passed by the third respondent.

3. The appellant company is engaged in manufacturing and selling of Active Pharmaceutical Ingredients (APIs), amino acids and their intermediates, primarily to the customers in the International markets. The appellant company is assessed to income tax under the jurisdiction of the First Respondent. During the previous year, relevant to the assessment year 2013-2014, the appellant had issued credit notes aggregating to Rs.11,96,04,791/- and claimed the same amount as deduction in the original return of income filed by it. Subsequently, the Authorized D