JUDGMENT :

(PER : HONOURABLE MR. JUSTICE BHARGAV D. KARIA)

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

2. Rule returnable forthwith. Learned Senior Standing Counsel Mr.Karan Sanghani waives service of notice of rule for the respondent.

3. Having regard to the controversy in narrow compass, with the consent of learned advocates for the respective parties, the matter is taken up for hearing.

4. By this petition under Article 226 of the Constitution of India, the petitioner has challenged the notice dated 27.03.2021, issued under Section 148 of the Income Tax Act, 1961 (for short “the Act”) for reopening of the Assessment for the year 2014-15.

5. The brief facts of the case are that for the Assessment Year 2014-15, the petitioner submitted the return of income on 24.11.2014 computing total income at Rupees NIL.

5.1. The case of the petitioner was selected for scrutiny assessment and notice dated 28.08.2015 under Section 143 of the Act followed by notice dated 08.04.2016 under Section 142(1) of the Act were issued requiring the petitioner to furnish various details stated therei