IN THE HIGH COURT OF GUJARAT AT AHMEDABAD R/SPECIAL CIVIL APPLICATION NO. 19606 of 2021 With R/SPECIAL CIVIL APPLICATION NO. 18900 of 2021 With R/SPECIAL CIVIL APPLICATION NO. 19330 of 2021 With R/SPECIAL CIVIL APPLICATION NO. 19620 of 2021 With R/SPECIAL CIVIL APPLICATION NO. 19630 of 2021 With R/SPECIAL CIVIL APPLICATION NO. 19686 of 2021 With R/SPECIAL CIVIL APPLICATION NO. 19689 of 2021 With R/SPECIAL CIVIL APPLICATION NO. 19690 of 2021 With R/SPECIAL CIVIL APPLICATION NO. 19761 of 2021 With R/SPECIAL CIVIL APPLICATION NO. 19769 of 2021 With R/SPECIAL CIVIL APPLICATION NO. 19771 of 2021 With R/SPECIAL CIVIL APPLICATION NO. 19952 of 2021 With R/SPECIAL CIVIL APPLICATION NO. 19954 of 2021 With R/SPECIAL CIVIL APPLICATION NO. 19964 of 2021 With R/SPECIAL CIVIL APPLICATION NO. 19997 of 2021 With R/SPECIAL CIVIL APPLICATION NO. 19998 of 2021 With R/SPECIAL CIVIL APPLICATION NO. 2004 of 2022 With R/SPECIAL CIVIL APPLICATION NO. 2042 of 2022 With R/SPECIAL CIVIL APPLICATION NO. 2050 of 2022 With R/SPECIAL CIVIL APPLICATION NO. 2531 of 2022 With R/SPECIAL CIVIL APPLICATION NO. 2587 of 2022 With R/SPECIAL CIVIL APPLICATION NO. 2660 of 2022 With R/SPECIAL CIVIL APPLICATION NO. 2695 of 2022 With R/SPECIAL CIVIL APPLICATION NO. 13094 of 2022 FOR APPROVAL AND SIGNATURE:

HONOURABLE MR. JUSTICE A.S. SUPEHIA sd/-

and HONOURABLE MR. JUSTICE PRANAV TRIVEDI sd/-

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Approved for Reporting Yes No √

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MANTHAN HEMANTKUMAR LALA Versus INCOME TAX OFFICER, WARD 6(1)(1) & ANR.

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Appearance in SCA 19606/2021, SCA No. 18900/2021, SCA No. 19630/2021, SCA No. 19761/2021, SCA No.19769/2021, SCA No.

19771/2021, SCA No. 2050/2022:-

MR TUSHAR HEMANI SENIOR ADVOCATE with MS VAIBHAVI K PARIKH(3238) for the Petitioner(s) No. 1 MR.VARUN K.PATEL(3802) for the Respondent(s) No. 1,2 MR KARAN SANGHANI for the Respondent (s)

Appearance in SCA No. 19686/2021:-

MR JIMI S PATEL for the Petitioner(s)

MR VARUN K PATEL for the Respondent(s)

Appearance in SCA No.19620/2021, SCA No.19552/2021, SCA No. 19954/2021, SCA No. 19964/2021, SCA No. 19997/2021, SCA No. 19998/2021:-

MR HARDIK V VORA for the Petitioner(s)

MR VARUN K PATEL for the Respondent(s)

in SCA No. 19964/2021:

MR AADITYA BHATT for Respondent(s)

Appearance in SCA No. 2042/2022, SCA No.2004/2022, SCA No.

2531/2022, SCA No. 2587/2022, SCA No. 2660/2022, SCA No. 2695/2022:-

MR DHINAL A SHAH for the Petitioner(s)

MR VARUN K PATEL for the Respondent(s)

Appearance in SCA No.19689/2021 & in SCA No.19690/2021 MR SN DIVATIA for the Petitioner(s)

MR MR MAUNIL YAJNIK for the Respondent(s)

Apperance in SCA No. 13094/2022 MR NIRAV P SHAH for the Petitioner MR NAITIK N SHAH for the Petitioner MS MAITHILI D MEHTA for the Respondent ==========================================================

CORAM:HONOURABLE MR. JUSTICE A.S. SUPEHIA and HONOURABLE MR. JUSTICE PRANAV TRIVEDI Date : 13/02/2026

ORAL JUDGMENT

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

1. Heard learned Senior Advocate Mr.Tushar Hemani appearing with Learned Advocate Ms.Vaibhavi K. Parikh and learned advocates Mr.Hardik V. Vora, Mr Dhinal A. Shah, Mr. Jimi S. Patel, Mr. S N Divatia and Mr. Nirav P. Shah for the petitioners and learned Senior Standing Counsels Mr.Varun K. Patel, Mr.Maunil Yajnik, Mr.Karan Sanghani, Ms. Maithili D Mehta and Mr.Aaditya Bhatt for the Revenue in the respective petitions.

2. The issue raised in the captioned writ petitions pertains to the re-

opening of the assessments issued under Section 153C of the Income Tax Act, 1961(hereinafter referred to as “the Act”) beyond the block period of 6 or 10 years and also for those years, wherein no incriminating material is found involving the assessee.

3. For the sake of relevance, Special Civil Application No. 19606 of

2021 is taken as a lead matter and the facts are referred to therefrom.

4. The petitioner has assailed the validity of the notices dated

28.04.2021 iss