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2023 Supreme(Guj) 666

N. V. ANJARIA, NIRAL R. MEHTA
Astron Zircon Private Limited – Appellant
Versus
Asstt. Commissioner Of Income Tax, Circle 1(1)(1) – Respondent


Advocates Appeared:
For the Petitioner: Mr. S.N. Divatia.
For the Respondent: Mr. Varun Patel.

ORDER :

(N.V. Anjaria, J.)

1. The Special Civil Application seeks to challenge the notice issued for re-opening of the assessment for the assessment year 2013-2014 under Section 148 and the orders passed under Section 148A(d) of the Income Tax Act, 1961.

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, the petition was taken up for final consideration today.

2. Rule, returnable forthwith. Learned advocate Mr. Varun Patel waives service of Rule for the respondent.

2.1 Heard learned advocate Mr. S. N. Divatia for the petitioner and learned advocate for the respondent.

3. In the present petition filed under Article 226 of the Constitution, the petitioner has 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. Also challenged is the order passed under Section 148A(d) of the Income Tax Act, 1961 (hereinafter referred to as "the Act").

3.1 The details of d

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