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NEUTRAL CITATION

C/SCA/3180/2026 JUDGMENT DATED: 24/03/2026

0.6263650243304917

IN THE HIGH COURT OF GUJARAT AT AHMEDABAD R/SPECIAL CIVIL APPLICATION NO. 3180 of 2026

FOR APPROVAL AND SIGNATURE:

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

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Approved for Reporting Yes No ✔

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NEWTURN AUTOMATION PRIVATE LIMITED Versus INCOME TAX OFFICER, WARD NO. 3(1)(1), AHMEDABAD

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Appearance:

MR MANISH BHATT SENIOR ADVOCATE with VIJAY H PATEL(7361) for the Petitioner(s) No. 1 AADITYA D BHATT(8580) for the Respondent(s) No. 1

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CORAM:HONOURABLE MR. JUSTICE A.S. SUPEHIA and HONOURABLE MR. JUSTICE PRANAV TRIVEDI

Date : 24/03/2026 ORAL JUDGMENT

(PER : HONOURABLE MR. JUSTICE PRANAV TRIVEDI)

1. Learned Senior Standing Counsel Mr. Aaditya Bhatt appearing for the respondent has tendered the affidavit-in-reply. The same is taken on

record.

2. Heard learned Senior Advocate Mr. Manish Bhatt assisted by learned advocate Mr. Vijay H. Patel for the petitioner and learned Senior

Standing Counsel Mr. Aaditya Bhatt for the respondent.

3. Rule returnable forthwith. Learned Senior Standing Counsel Mr.

Aaditya Bhatt waives service of notice on behalf of the respondent.

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NEUTRAL CITATION

C/SCA/3180/2026 JUDGMENT DATED: 24/03/2026

0.6263650243304917

4. By way of this petition under Article 226 of the Constitution of India, the petitioner has prayed for a direction to quash and set aside the impugned order dated 27.08.2024 passed under Section 148A(d) of the Income Tax Act, 1971 (for short “the Act”), the impugned notice dated 27.08.2024 passed under Section 148 of the Act as well as the Assessment Order dated 18.02.2026 passed under Section 147 of the Act read with

Section 144B of the Act.

5. The brief facts leading to filing of the present writ petition is that the petitioner is a Company incorporated under the provisions of the Companies Act, 2013 and is inter alia into the business of trading and marketing of parking lift, boom barriers and gate automation. The petitioner filed its return of income under Section 139(1) of the Act declaring total income of Rs.55,64,410/- qua the Assessment Year 2018-19. Subsequent to the filing of the return of income, the case of the petitioner was flagged on insight portal and therefore, the petitioner was served with the notice under Section 148A(b) of the Act for the Assessment Year under consideration. The petitioner was called upon to explain as to why notice

under Section 148 of the Act should not be issued against the petitioner.

5.1. It is the case of the petitioner that the petitioner immediately responded to the notice by way of reply dated 02.08.2024 demanding details as relied upon by the respondent authority as well as by submitting the computation of income and bank statements. The details as demanded by the petitioner were supplied to the petitioner on 16.08.2024. However, the respondent authority passed the impugned order under Section

148A(d) of the Act on 27.08.2024.

4.2. It is the case of the petitioner that the subsequent to the order under Section 148a(d) of the Act, the respondent issued notice under Section 143(2) of the Act on 19.06.2025 and thereafter the petitioner was served with the notice under Section 142(1) of the Act on 03.09.2025

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NEUTRAL CITATION

C/SCA/3180/2026 JUDGMENT DATED: 24/03/2026

0.6263650243304917

calling upon the petitioner to submit its financial records. Thereafter a final show cause notice was issued on 23.01.2026 to which the petitioner filed its reply on 01.02.2026. The Assessment Order under Section 147 of the Act read with Section 144B of the