ORDER :

(PER : HONOURABLE MR. JUSTICE J.B.PARDIWALA)

1. Since the subject matter of both the writ applications is the same and the assessee is also the same, those were taken up for hearing analogously and are being disposed of by this common order.

2. For the sake of convenience, we treat the Special Civil Application No.16265 of 2019 as the lead matter.

3. By this writ application under Article 226 of the Constitution of India, the writ applicant - a partnership firm has prayed for the following reliefs:

“(a) To issue a writ of certiorari or a writ in the nature of certiorari or any other appropriate writ, orders or directions quashing and setting aside the impugned notice dated 30.03.2019 [Annex.A] issued by the Respondent proposing to reopen the completed assessment of the Petitioner for A.Y. 2012-13 and the order of objection dt.23-7-2019 (Annexure-B) as well as the reassessment order, if any passed in consequence to the impugned notice.

(b) to call for the records of the proceedings, look into them and be pleased to issue a writ of certiorari or any other appropriate writ, order or direction quashing the impugned notice as well as the order of objection dt.23-7-2019 (Annx.B).

(c) Pe