JUDGMENT :

(Bhargav D. Karia, J.)

1. Heard learned advocate Mr. Manish J. Shah for the petitioner and learned Senior Standing Counsel Mr. Nikunt Raval for learned advocate Mrs. Kalpana K. Raval for the respondent.

2. Rule. Learned Senior Standing Counsel Mr. Nikunt Raval waives service of notice of rule on behalf of the respondent.

3. By these petitions under Article 226 of the Constitution of India the petitioner has challenged the order dated 17.05.2023 passed under section 254(2) of the Income Tax Act,1961 (for short ‘the Act’) in Misc. Application preferred by the petitioner being M.A. No. 100/Ahd/2022 in ITA No. 445/Ahd/18 in Special Civil Application No. 20400/2023, M.A.No. 97/Ahd/2022 in ITA No. 2089/Ahd/2013, M.A.No. 99/Ahd/2022 in ITA No. 1751/Ahd/2016.

4. Brief facts of the case in all the three petitions are of the same assessee pertaining to the three different assessment years. Therefore, the same are heard together and are being disposed of by this Common order.

5. For the sake of convenience, facts of Special Civil Application No. 20400/2023 is considered as lead case. The petitioner-Company is owned by the Government of Gujarat carrying on business of distribution of ele