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2024 Supreme(Online)(GUJ) 25550

HIGH COURT OF GUJARAT
MR. JUSTICE BHARGAV D. KARIA, MRS. JUSTICE MAUNA M. BHATT, JJ
CHANDRIKA DHANSUKHLAL GANDHI – Appellant
Versus
ASSISTANT COMMISSIONER OF INCOME TAX CIRCLE 1(2) – Respondent


Advocates:
MR MANISH J SHAH for the Petitioner(s) No. 1, MRS KALPANA K RAVAL for the Respondent(s) No. 1

Table of Content
1. petitioner challenges notice validity (Para 4 , 5 , 6 , 7 , 8)
2. assessing officer's reasoning inadequate (Para 9 , 10 , 11)
3. notice quashed and set aside (Para 12)

ORAL 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 learned advocate 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 and on behalf of the respondent No.1.

3. Having regard to the controversy in narrow compass, with the consent of the learned advocates for the 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 the validity and legality of the notice issued under Section 148 of the Income Tax Act, 1961 (for short ‘the Act’) for Assessment Year 2013-14.

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

5.1. The petitioner filed her return of income declaring the total income of Rs.5,98,540/- on 30th July, 2013 for Assessment Year 2013-14.

5.2. Thereafter, the petitioner receive

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