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N. V. ANJARIA, NIRAL R. MEHTA
MEHUL KANTILAL PATEL – Appellant
Versus
INCOME TAX OFFICER, SURAT – Respondent
JUDGMENT :
N.V. ANJARIA, J.
1. All these Special Civil Applications seeking to challenge the notices issued for re-opening of the assessment for the assessment years concerned under Section 148 and the orders passed under Section 148A(d) of the Income Tax Act, 1961.
1.1 The petitions involve similar facts and identical issues, therefore, they were heard together to be treated for disposal by this common judgment and order.
1.2 In the facts and circumstances of the case, having regard to the issues involved and with consent and request of learned advocates for the parties, all these Special Civil Applications were taken up for final consideration today.
2. Rule returnable in each of the Special Civil Applications forthwith. Learned advocate Mr. Varun K. Patel with learned advocate Mr.Dev Patel for the respondent Revenue and learned advocate Mr.Nikunt Raval with learned advocate Ms.Kalpana Raval for the respondent in respective matter, waives service of Rule in all.
2.1 Heard learned advocate Mr.Hiren Trivedi for the petitioners and learned advocate for the respondent.
3. In the present
The main legal point established in the judgment is that notices for reopening assessment must be issued within the permissible time limit as prescribed by the relevant provisions of the Income Tax A....
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