IN THE HIGH COURT OF GUJARAT AT AHMEDABAD R/SPECIAL CIVIL APPLICATION NO. 20749 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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SHRUTI PIYUSHBHAI SHAH Versus DEPUTY 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 : 03/03/2026 ORAL JUDGMENT (PER : HONOURABLE MR. JUSTICE A.S. SUPEHIA)

1. Heard learned advocate Mr. Dhinal Shah 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 25.08.2022 (only intimation was issued and notice was not served) along with order under Section 148A(d) dated