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2021 Supreme(Guj) 82

J.B.PARDIWALA, ILESH J.VORA
Kantibhai Dharamshibhai Narola – Appellant
Versus
Assistant Commissioner Of Income Tax, Ward – Respondent


Advocates:
Advocate Appeared:
For the Appellant :Mr Tushar Hemani, Sr.Advocate with Ms Vaibhavi K.Parikh, adv.
For the Respondent: Mrs Kalpanak Raval, adv

JUDGMENT :

HONOURABLE MR. JUSTICE J.B.PARDIWALA, J.

1. Since the issues raised in all the captioned writ-applications are interrelated, those were heard analogously and are being disposed of by this common judgment and order.

2. For the sake of convenience, the Special Civil Application No.19549 of 2018 is treated as the lead matter.

3. By this writ-application under Article 226 of the Constitution of India, the writ-applicant seeks to challenge the legality and validity of the notice dated 28th March 2018 (Annexure-A to the writ-application) issued by the respondent under Section 148 of the Income Tax Act, 1961 (for short, 'the Act 1961') seeking to reopen the writ-applicant's income tax assessment for the Assessment Year 2011-12 on the ground of being illegal, contrary to law and without jurisdiction.

4. The facts giving rise to this writ-application may be summarised as under :

5. The writ-applicant derived income from a partnership firm, salary, capital gains and income from other sources during the Assessment Year 2011-12, i.e. the year under consideration.

6. It appears from the

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