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N. V. ANJARIA, NIRAL R. MEHTA
Priyawart Dipakbhai Jariwala – Appellant
Versus
Income Tax Officer, Ward 1(3)(1) – Respondent
JUDGMENT :
(N.V. Anjaria, J.)
In the facts and circumstances of the case, having regard to the issue involved and with consent and request of learned advocates for the parties, this Special Civil Application was taken up for final consideration today.
2. Rule returnable forthwith. Learned advocate Mrs. Kalpana Raval for the respondent Revenue waives service of Rule.
2.1 Heard learned advocate Mr. Yogesh B. Shah 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 dated 21.07.2022 issued by respondent-assessing officer under Section 148 of the Income Tax Act, 1961 seeking to reopen the assessment in respect of assessment year 2014-15. Also challenged is the order dated 21.07.2022 passed under Section 148A(d) of the Income Tax Act, 1961 (hereinafter referred to as "the Act").
3.1 While in the impugned order under section 148A(d) of the Act mentioned are the factual details and the reasons on the basis of which the assessing officer has found that the case is fit to be reopened for the assessment in respect of the year under consideration, it is inter alia sta
The main legal point established in the judgment is the interpretation of the time limits for issuing notices for reopening assessments under the Income Tax Act, 1961, and the impact of the changes b....
The main legal point established in the judgment is that notices issued under section 148 of the Income Tax Act, 1961 between 01.04.2021 to 30.06.2021, relating to the assessment years 2013-14 and 20....
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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