1. The instant writ Petition arises out of the reassessment proceedings
for the Assessment Year 2010-11 under the provisions of Section
147/143(3) read with section 148 of the Income Tax Act, 1961
(hereinafter referred to as the said Act).
2. Apropo, the facts of the case is that the assessee filed its return of
income to the tune of Rs. 29,56,452/- for the Assessment Year 2010-
11 on September 10, 2010. The case was accordingly processed
under Section 143(1) of the said Act. Subsequently the information
was received from the Directorate of Income Tax (Intelligence and
Criminal Investigation) Kolkata (herein after referred to as DIT (INV)
for the sake of brevity and convenience) about booking loss of Rs.
14,44,92,868/- by the assessee through client code modification. The
said fact was brought to the notice of the said DIT (INV) during the
spot verification and inspection conducted under Section 131(1A) of
the said Act. The case was reopened by issuing notice under Section
148 of the said Act on March 23, 2015 after recording the reasons for
reopening. The said reasons were communicated to the assessee
upon request made for the same.
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