JUDGMENT :

ILESH J. VORA, J.

1. As the common questions of law and fact arise in the captioned writ applications with respect to different assessees for the same year i.e. A.Y. 2015-16, were heard analogously and are being disposed of by this common judgment and order.

2. By these writ applications under Article 226 of the Constitution of India, the writ applicants seek to challenge the legality and validity of the Notice dated 28.03.2018 issued by the respondent under Section 148 read with Section 147 of the Income Tax Act, 1961 (‘the Act’ for short), seeking to reopen the writ applicants’ income tax assessment for the A.Y. 2015- 16.

3. Brief facts giving rise to filing present writ applications are as follows:-

SCA No.19093/2018 (Hareshbhai Mathurbhai Zinzuvadia):-

3.1 The writ applicant being an individual assessee filed his return of income on 23.09.2015 declaring total income at Rs.3,73,32,220/-. The return of income was processed under Section 141 of the Act and no scrutiny assessment was undertaken.

SCA No.19068/2018 ( Darshit Ashokbhai Zinzuvadia):-

3.2 The writ applicant being an i