Indira Banerjee, J. - (1.) IN this writ application, the petitioner has, inter alia, challenged a notice dated August 28, 2003, issued to the petitioner by the Assessing Officer under Section 148 of the Income Tax Act, 1961, hereinafter referred to as the Income Tax Act, for reopening the assessment of the petitioner for the assessment year 1999 -2000.
(2.) ON December 28, 1999, the petitioner submitted a return of its income for the assessment year 1999 -2000 under Section 139 of the Income Tax Act, disclosing total income of Rs. 6,76,22,600. The petitioner later filed a revised return on March 29, 2001, disclosing an income of Rs. 3,48,84,790. 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.
(3.) THE Assessing Officer did not issue any notice of inquiry in respect of the return under Section 142(1) of the Income Tax Act. Nor did the Assessing Officer issue any notice under Section 143(2) of the Income Tax Act calling upon the petitioner to substantiate any claim in the return of any loss, exemption, deduction, allowance or relief.;