(1.) Rule having been issued previously, we have heard learned counsel for the parties on final hearing.
(2.) Petitioner has challenged a notice of reopening of assessment dtd. 30/3/2018.
(3.) Brief facts are as under:- Petitioner is Asset Reconstruction Company India Private Limited ("ARCIL" for short) and is engaged in the business of securitisation and asset reconstruction and also acts as trustees for the non-performing financial assets acquired from the various banks and financial institutions.