IN THE HIGH COURT OF GUJARAT AT AHMEDABAD R/SPECIAL CIVIL APPLICATION NO. 8645 of 2022 FOR APPROVAL AND SIGNATURE:

HONOURABLE MR. JUSTICE A.S. SUPEHIA and HONOURABLE MR. JUSTICE PRANAV TRIVEDI ==================================================

Approved for Reporting Yes No ✔

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DIGNESH PRAMUKHLAL PATEL Versus ASSISTANT COMMISSIONER OF INCOME TAX CIRCLE 3(1)(1), AHMEDABAD ==================================================

Appearance:

MR DHINAL A SHAH(12077) 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 : 10/03/2026 ORAL JUDGMENT (PER : HONOURABLE MR. JUSTICE PRANAV TRIVEDI)

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

2. Having regard to the controversy arising in this petition, which is in a narrow compass, with the consent of the learned advocates for the respective parties, the same is taken up for final hearing. Initially the present petition was admitted on the ground of the jurisdi