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N. V. ANJARIA, NIRAL R. MEHTA
DIVYANGBHAI JAYENDRABHAI SHAH – Appellant
Versus
DEPUTY COMMISSIONER OF INCOME TAX – Respondent
JUDGMENT :
N.V. ANJARIA, J.
1. Leave to amend is granted in Special Civil Application No. 4442 of 2023. To be carried out forthwith.
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 advocates Mrs. Kalpana K. Raval and Mr. Varun Patel for the respondent Revenue waive service of Rule in the respective petitions.
2.1 Heard learned senior advocate Mr. Tushar Hemani assisted by learned advocate Mr. Parimalsinh Parmar for the petitioners and
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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