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2024 Supreme(Guj) 1548

BHARGAV D. KARIA, NIRAL R. MEHTA
Arunbhai Maneklal Jhaveri And Sons Through Partner Rajubhai Arunbhai Jhaveri – Appellant
Versus
Deputy Commissioner of Income Tax Circle 2(1)(1) – Respondent


Advocates Appeared:
For the Petitioner: Ms. Nupur D. Shah.
For the Respondent: Mr. Varun K. Patel.

ORDER :

Bhargav D. Karia, J.

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

    “8.1 That the Hon’ble Court be pleased to issue a writ of mandamus or a writ in the nature of mandamus or any other appropriate writ, order or direction quashing and setting aside the impugned notice dated 30.03.2021 issued u/s. 148 of the Income Tax Act by the respondent (Annexure-E) as well as the order dated 11.11.2021 disposing off the objections against the reasons recorded (Annexure-H).”

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

2.1 The petitioner is a partnership firm established on 1st April 1994. The petitioner filed the return of income for the Assessment Year 2017-18 through electronic media on 29th October 2017 declaring total income of Rs.96,91,680/-.

2.2 Thereafter, the case of the petitioner was selected for scrutiny assessment under Section 143(3) of the Income Tax Act, 1961 (for short, “the Act”) and notice was accordingly issued by the Assessing Officer - ACIT, Circle 5(2)(1), Ahmedabad. During the course of assessment proceedings, various details and explanation were called for, all of which had been duly submitted on

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