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2025 Supreme(Guj) 1349

IN THE HIGH COURT OF GUJARAT AT AHMEDABAD
BHARGAV D.KARIA, PRANAV TRIVEDI
Jay Prabhu Industries Llp – Appellant
Versus
National Faceless Assessment Centre – Respondent


Advocates Appeared:
For the Appellant : MR MOHIT R BALANI
For the Respondent: MS MAITHILI D MEHTA

JUDGMENT :

BHARGAV D. KARIA, J.

1. Heard learned advocate Mr. Mohit R. Balani for the petitioner and learned Senior Standing Counsel Ms. Maithili Mehta for the respondents.

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

3. Rule returnable forthwith. Learned Senior Standing Counsel Ms. Maithili Mehta waives service of notice of rule on behalf of the respondents.

4. The petitioner M/s. Jay Prabhu Industries LLP, which was formerly a partnership firm known as ‘M/s. Jay Prabhu Cotton Industries’ has challenged the legality of the assessment order dated 28.03.2022 passed under Section 147 read with Section 144B of the INCOME TAX ACT , 1961 (For Short “the Act”) for the Assessment Year 2016-17 in the name of erstwhile partnership firm along with notice issued under Section 148 of the Act dated 27.03.2021 in name of the partnership firm.

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

5.1. The petitioner M/s. Jay Prabhu Cotton Industries, LLP was formed on 23.04.2014 on conversion from M/s. Jay Prabhu Cotton Industries a partnership firm as per the p

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