IN THE HIGH COURT OF GUJARAT AT AHMEDABAD R/SPECIAL CIVIL APPLICATION NO. 15560 of 2025 ==================================================

BABUBHAI GANESHBHAI PRAJAPATI Versus THE INCOME TAX OFFICER , WARD 3(3)(5)

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Appearance:

DARSHAN R PATEL(8486) for the Petitioner(s) No. 1 AADITYA D BHATT(8580) for the Respondent(s) No. 1 ==================================================

CORAM:HONOURABLE MR. JUSTICE A.S. SUPEHIA and HONOURABLE MR. JUSTICE PRANAV TRIVEDI Date : 03/12/2025

ORAL ORDER

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

1. Heard learned advocate Mr. Darshan Patel for the petitioner and learned Senior Standing Counsel Mr. Aaditya Bhatt for the respondent.

2. This petition is filed under Article 226 of the Constitution of India challenging the notice under section 148 of the Income Tax Act, 1961 (For short “the Act”) dated 30.08.2022 on the ground that the notice would be invalid and time barred.

3. Brief facts of the case are that the respondent Assessing Officer issued notice dated 30.06.2021 under section 148 of the Act for the Assessment Year 2017-2018 during the extended time period as per The Taxation and Other Laws (Relaxation