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2023 Supreme(Guj) 656

N. V. ANJARIA, NIRAL R. MEHTA
Seven Star – Appellant
Versus
Income Tax Officer, Ward 3(3)(1), Surat – Respondent


Advocates Appeared:
For the Petitioner: Jaimin A. Gandhi, Mr. Viresh I. Rudalal.
For the Respondent: Ms. Kalpana Raval.

JUDGMENT :

(N.V. Anjaria, J.)

All these Special Civil Applications seek 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 Ms. Kalpana Raval waives service of Rule in respective petition.

2.1 Heard learned advocate Mr. Jaimin Gandhi 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 Sec

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