IN THE HIGH COURT OF GUJARAT AT AHMEDABAD R/SPECIAL CIVIL APPLICATION NO. 707 of 2023 ==================================================

AMITA SAMIR SHAH Versus THE INCOME TAX OFFICER, WARD 4(2)(1), AHMEDABAD & ANR.

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Appearance:

MR MOHIT R BALANI(12259) for the Petitioner(s) No. 1 MS MAITHILI D MEHTA(3206) for the Respondent(s) No. 1,2 ==================================================

CORAM:HONOURABLE MR. JUSTICE A.S. SUPEHIA and HONOURABLE MR. JUSTICE PRANAV TRIVEDI Date : 02/12/2025

ORAL ORDER

(PER : HONOURABLE MR. JUSTICE A.S. SUPEHIA)

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

2. The petitioner has challenged notices issued under section 148 of the Income Tax Act, 1961 (for short “the Act”) for the Assessment Year 2015-2016 under the old regime in view of TOLA without issuing notice under section 148A(b) as required to be issued with effect from 01.04.2021.

3. Notice under section 148 under The Taxation and Other Laws (Relaxation of Certain Provisions) Ordinance, 2020 [(2020) 422 ITR (St.) 116] (For short “TOLA”) was issued on 08.04.2021 where