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 learned advocate for the respondent.

3. In the present petitions filed under Article 226 of the Constitution, the respective petitioners have called in question the notice issued by respondent-assessing officer under Section 148 of the Income Tax Act, 1961 seeking to reopen the assessment in respect of assessment year 2013-14 or assessment year 2014-15 as the case may be. Also challenged are the orders passed under Section 148A(d) of the Income Tax Act, 1961 (hereinafter referred to as “the Act”).

3.1 The details of date of notice, date of order under Section 148A(d) of the Act, assessment year, etc., in respect of all the petitioners are given in the table below: