JUDGMENT :

BHARGAV D. KARIA, J.

1. Learned advocate Mr. B.S. Soparkar for the petitioner tendered the draft amendment. The same is allowed in terms of the draft. To be carried out forthwith.

2. Heard learned Senior Advocate Mr. S.N. Soparkar assisted by learned advocate Mr. B.S.Soparkar for the petitioner and learned Senior Standing Counsel Mr. Varun Patel with learned advocate Mr. Dev D. Patel for respondent No.2.

3. Rule returnable forthwith. Learned advocate Mr. Dev D. Patel waives service of notice of rule for the respondent No.2.

4. Having regard to the controversy involved in this petition in narrow compass, with the consent of learned advocates appearing for the respective parties, the matter is taken up for final hearing.

5. By this petition under Articles 226 and 227 of the Constitution of India, the petitioner has prayed for the following reliefs:

“(a) Quash the order passed by the Respondent No.1 dated 27.12.2023 at Annexure A and Direct the Respondent No.1 to pass a fresh order u/s. 245D(4) in the case of the petitioner on merits and in accordance with law.

(aa) quash and set aside the assessment orders passed by the Respondent No.3 on 27.07.2021 for the Assessment years 2013-