- (1.) In this writ application, the petitioner has inter alia challenged a notice dated 28th August, 2003 issued to the petitioner by the Assessing Officer under section 148 of the Income Tax Act, 1961, hereinafter referred to as the I.T. Act, for reopening the assessment of the petitioner for the Assessment Year 1999-2000.
(2.) On 28th December, 1999, the petitioner submitted a return of its income for the Assessment Year 1999-2000 under section 139 of the I.T. Act, disclosing total income of Rs.6,76,22,600/-. The petitioner later filed a revised return on 29th March, 2001 disclosing an income of Rs.3,48,84,790/-.
(3.) The reduction of income was, according to the petitioner, by reason of decrease in the value of the stock in trade of Rajdoot Paints Ltd., which had been amalgamated with the petitioner, upon change in the accounting method and adoption of the accepted method of valuation of stocks, followed by the petitioner.;