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3. The assessee is a public sector construction company and 78.21% of equity shares are held by the President of India and operates through Ministry of Railway (MoR), Government of India. It implements various types of railway infrastructure projects assigned by MoR includes doubling (3rd/4th lines) gauge conversion, new lines railway electrification and major bridges.

4. It is relevant to note that the assessee has filed its return of income on 28.02.2022 and the case was selected for scrutiny on 28.06.2022 and subsequently, notice u/s 142 (1) dated 12.09.2022 was issued to the assessee and assessee submitted relevant information relating to various informations called for in questionnaire of notice u/s 142(1) of the Act on 26.08.2022.