JUDGMENT :

Devan M. Desai, J.

1. By way of this petition filed under Article 226 of the Constitution of India, the petitioner has sought for the following reliefs :

“7A. quash and set aside the impugned notice dated 25.03.2021 issued by the Respondent under Section 148 of the Income Tax Act, 1961 for the Assessment Year 2017-18 at Annexure ‘A’;

B. pending the admission, hearing and final disposal of this petition, to stay implementation and operation of the notice at Annexure A to this petition and stay further proceedings for assessment and recovery for A.Y.2017-18;

C. any other and further relief deemed just and proper be granted in the interest of justice;

D. to provide for the cost of this petition.”

2. By consent of both the learned advocates, the present petition has taken up for final hearing.

3. Heard the learned advocate Mr. B.S. Soparkar for the petitioner and the learned Standing Counsel Mr. Karan Sanghani for the respondent.

4. Rule. Learned Standing Counsel Mr. Sanghani for the respondent waives service of notice of rule for and on behalf of respondent.

5. Learned advocate for the petitioner has submitted that the Scheme of arrangement in the nature of amalgamation of the erstwh