2014 (8) TMI 598

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....y way of this petition under Article 226 of the Constitution of India, the petitioner has prayed for an appropriate writ, direction or order to quash and set aside the impugned notice, Dated : 11.03.2013, Annexure-A to the petition, by which the assessment for the A.Y. 2009-2010 is sought to be reopened in exercise of powers under Section 147 of the Income Tax Act. 4. The assessment proceedings for the year under consideration, i.e. A.Y. 2009-10, came to be concluded vide assessment order dated 24.12.2010. The impugned notice under Section 147 of the Act came to be issued on 11.03.2013. At the instance of the petitioner-assessee, the AO provided the reasons for reopening of the assessment vide communication dated 03.12.2003. That, therea....

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....titioner-assessee, has heavily relied on a decision of the Division Bench of this Court in the case of "COMMISSIONER OF INCOME TAX, AHMEDABAD, IV, VS. SHILP GRAVURES LTD.", reported in [2013] 40 Taxmann 309 (Gujarat) as well as in the case of "VODAFONE WEST LTD. VS. ASST. COMMISSIONER OF INCOME TAX", [2013] 37 Taxmann 158 (Gujarat). He has also relied upon a recent decision of this Court, Dated : 08.07.2014, rendered in the case of "MAYUR WOVENS PVT. LTD. VS. INCOME TAX OFFICER AND ANR." in Special Civil Application No. 3707 of 2014 and Special Civil Application No. 3708 of 2014 . 7. Making the above submissions, it is requested to quash and set aside the impugned notice of reassessment. 8. Shri. Varun K. Patel, learned Advocate, has ....