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2021 Supreme(Guj) 176

J.B.PARDIWALA, ILESH J.VORA
GARVIT DIAMONDS PVT. LTD. – Appellant
Versus
INCOME TAX OFFICER – Respondent


Advocates Appeared:
For the Petitioner: MR OMKAR C DAVE
For the Respondent: MRS KALPANAK RAVAL

ORDER :

ILESH J. VORA, J.

1. By filing this writ application under Article 226, the writ applicant seeks to challenge the notice dated 31.03.2019 issued by the respondent under Section 148 of the Income Tax Act, 1961 (‘the Act’ for short) seeking to reopen the applicant’s income tax assessment for the A.Y 2012-13.

2. The brief facts leading to file the present writ application can be summarized as under:

    2.1 The writ applicant – assessee Company filed its return of Income for the A.Y. 2012-13 on 07.02.2013 declaring total income at Rs. 1,75,310/and assessment under Section 143(3) of the Act was completed on 26.03.2015.

2.2 The Assessing Officer has reopened the assessment under Section 147 by issuing impugned notice dated 31.03.2019 under Section 148 of the Act.

2.3 At the request of the writ applicant, reasons recorded have been furnished to the writ applicant on 17.05.2019, which reads as under :

REASONS RECORDED :

1. The assessee Company has its return of income for AY 2012-13 on 07.02.2013 declaring total income at Rs.1,75, 310/. The assessment u/s 143(3) was completed on 26.03.2015.

2. In

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