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JUDGMENT Siddharth Mridul, J. - By way of this writ petition a writ of certiorari has been sought for quashing the notice dated 28.03.2013 issued by the respondent (Deputy Commissioner of Income Tax) under Section 148 of the Income Tax Act, 1961 (hereinafter referred to as 'the said Act'). 2. The facts of the present writ petition are enunciated as below:- 3. On 29.11.2006 the petitioner/assessee filed its return of income for the assessment year 2006-2007. The aforesaid return of income of the petitioner was selected for scrutiny assessment vide issue of notice under Section 143(2) of the said Act dated 28.09.2007. 4. On 20.12.2007 the assessing officer issued another notice along with the detailed questionnaire raising queries on 32 points. Vide the said questionnaire, the assessing officer with respect to query No.1 required the petitioner/assessee to submit the audited account along with the audit report. Further, with respect to query No.9, the assessing officer required the petitioner/assessee to submit the details with regard to the loans taken by the petitioner/assessee, requiring information with respect to the opening balance, addition, repayment, rate of interest, interest accrued, interest received etc. Further, with respect to query No.12 of the said questionnaire the assessing officer required the petitioner/assessee to submit details with respect to loans and advances given by the petitioner/assessee along with the details with respect to rates of interest on advances, interest received on advances etc. 5. On 23.07.2008 the petitioner/assessee submitted its response with respect to the questionnaire issued by the assessing officer. With respect to query No.1, the petitioner/assessee submitted the auditor's report and audited accounts. In the said auditor's report, the auditor had mentioned that the petitioner/assessee has given interest free loans/advances to group companies totaling to Rs.5,20,57,726/- as at the year-end. In the said report, the auditor has also commented that the terms and conditions of the said advances are not prima facie prejudicial to the interest of the petitioner/assessee. Further, it was commented that the disclosure…

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