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2025 Supreme(GUJ) 693

HIGH COURT OF GUJARAT
BHARGAV D. KARIA, J,DNR
HASMUKHBHAI GIRDHARILAL CHOPRA – Appellant
Versus
THE NATIONAL FACELESS ASSESSMENT CENTRE GOVT. OF INDIA – Respondent


Petitioner Advocates:MS VAIBHAVI K PARIKH(3238) ,Respondent Advocate: MR.VARUN K.PATEL(3802)

ORDER :

(BHARGAV D. KARIA, J.)

1. Heard learned Senior Advocate Mr.Tushar Hemani with learned advocate Ms.Vaibhavi K. Parikh for the petitioner and learned Senior Standing Counsel Mr.Varun K. Patel with learned advocate Mr.Dev D. Patel for the respondents.

2. This petition is filed challenging the Assessment Order dated 29.03.2022 passed by the respondent under Section 147 read with Section 144B of the Income Tax Act, 1961 (for short ‘the Act’) and demand notice of even date issued under Section 156 of the Act for Assessment Year 2014-15 on the ground that there is violation of principles of natural justice and non-consideration of the reply filed by the petitioner in response to the show-cause notice dated 24th March, 2022.

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

3.1. During the year under consideration, the petitioner was engaged in the business of wholesale as well as retail business of gold and silver bullion and jewellery. The Petitioner filed his return of income on 07.11.2014 declaring total income at Rs.8,07,529/-.

3.2. Thereafter, the case of the petitioner was reopened by issuance of notice dated 31.03.2021 under Section 148 of the Act. The respondent vide notice dated 24

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