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2021 Supreme(Guj) 468

BELA M.TRIVEDI, ASHOKKUMAR C.JOSHI
Zaveri and Company Private Limited – Appellant
Versus
Deputy Commissioner of Income Tax – Respondent


Advocates:
Advocate Appeared:
For the Petitioners: Mr. R.K. Patel, Mr. Darshan R. Patel.
For the Respondents: Mr. M.R. Bhatt, Mrs. Mauna M. Bhatt.

JUDGMENT :

BELA M. TRIVEDI, J.

1. The present petition filed by the petitioner-Zaveri and Company Private Limited through its Director-Kishor Pranjivandas Mandalia, under Article 226/227 of the Constitution of India, is directed against the impugned notice dated 30.03.2019 (Annexure-F) issued under section 148 of the Income Tax Act, 1961, (hereinafter referred to as ‘the said Act’) and the order dated 10.10.2019 (Annexure K) passed by the respondent rejecting the objections filed by the petitioner against the said notice.

2. The facts in nutshell as emerging from the record of the petition are that the petitioner-company is engaged in the business of manufacturing and trading in jewellery, bullion trading, trading and speculation in commodities, shares and securities, units of mutual funds and derivatives, generation and sales of electric power through windmills and trading in SEZ unit as well as gold and silver refinery business. The petitioner had filed the return for the A.Y. 2012-13 and thereafter had filed a revised return. After the scrutiny assessment having been undertaken on various points and after issuing the show-cause notice, the Assessing Officer had framed the assessmen

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