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2023 Supreme(Guj) 78

ARAVIND KUMAR, ASHUTOSH J. SHASTRI
Pavan Kishanchand Tulsiani – Appellant
Versus
Union Of India – Respondent


Advocates:
Advocate Appeared:
For the Appellant : MR BRIHAN R MADHAV

JUDGMENT :

ARAVIND KUMAR, J.

1. These three Special Civil Applications are filed by same assessee and on account of issue involved being common these Special Civil Applications are taken up together for consideration and disposed of by this common judgment by narrating the facts of each case chronologically hereinbelow.

2. Petitioner seeks to challenge the legality of re-opening of the assessment in all these petitions by issuance of impugned notices and passing of the impugned orders raising several contentions.

RE: SCA No. 19274 OF 2018

3. Petitioner is a Director/Partner in various firms and derives income from various sources. For the Assessment Year 2011-12, petitioner filed the return of income by declaring his income to the tune of Rs.1,00,85,160/- and paid tax to the tune of Rs.33,45,909/-. A notice dated 30.3.2018 under Section 148 of the Income Tax Act, 1961 (‘the Act’ for short) was issued for re-assessing the income and called upon the petitioner to file his return of income in the prescribed form for the said assessment year. On 29.8.2018, the assessee filed the reply d

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