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2014 Supreme(Guj) 737

M.R.SHAH, K.J.THAKER
ANIL HASSANAND GAJWANI – Appellant
Versus
INCOME TAX OFFICER – Respondent


Advocates:
Advocate Appeared:
MR MANISH J SHAH, ADVOCATE for the Petitioner(s) No. 1 MR NITIN K MEHTA, ADVOCATE for the Respondent(s) No. 1

JUDGMENT

M.R. SHAH, J.

1.0. By way of this petition under Article 226 of the Constitution of India, the petitioner has challenged the impugned notice for reopening of the assessment issued under Section 148 of the Income Tax Act (hereinafter referred to as the “Act”) which has been issued beyond the period of four years from the end of the assessment year.

2.0. It is the case on behalf of the petitioner that petitioner filed return of income for the assessment year 2006-07 showing the total income of Rs.76,67,256/-. It is the case on behalf of the petitioner after filing the return of income, the petitioner received a notice dated 19.06.2008 calling for certain details. That another notice under Section 143(2) of the Act dated 25.08.2008 was received by the petitioner and in response to the said notice, the petitioner filed his reply on 11.08.2008 with the details called for. That another notice under Section 143(2) dated 25.08.2008 was issued to that also the petitioner filed letter in response to the above facts and asked for some time to file further details which had been called for. It is the case on behalf of the petitioner that thereafter the petitioner through another letter d







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