JUDGMENT :

BHARGAV D. KARIA, J.

1. Heard learned advocate Mr.Jimi S. Patel for the petitioner and learned Senior Standing Counsel Mr.Karan Sanghani for Mrs.Kalpana K.Raval for the respondent no.1.

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

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 and 227 of the Constitution of India, the petitioner has prayed for the quashing and setting aside notice dated 28.03.2021 for the assessment year 2013-14.

5. The brief facts of the case are as under:

5.1. The petitioner filed return of income for the Assessment Year 2013-14 on 31.10.2013 declaring total income of Rs.12,83,920/-. The petitioner had offered its entire income under the head “Income from Business and Profession” which arose on account of sale of land situated at Santej.

5.2. The petitioner had sold land situated at Block no.510, Revenue Survey No.473 and Block No.512, Revenue Survey No.479 situated at Santej by executing tri-parte conveyance deed registered on