2022 (2) TMI 594

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....RE Appearance: MR S M DAVE(11268) for the Petitioner(s) No. 1 MR. JAIMIN R DAVE(7022) for the Petitioner(s) No. 1 PRIYANK S DAVE(9465) for the Petitioner(s) No. 1 MR MR BHATT SENIOR COUNSEL WITH MR KARAN SANGHANI, ADVOCATE FOR M R BHATT & CO.(5953) for the Respondent(s) No. 1 ORAL ORDER (PER : HONOURABLE MR. JUSTICE J.B.PARDIWALA) 1. By this writ application under Articl....

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.... Tax Act, 1961 (for short, "the Act, 1961") dated 31st March 2021 seeking to reopen the assessment for the A. Y. 2016-17 under Section 147 of the Act, essentially on the ground that the assessee failed to offer an amount of Rs. 52 Lakh for taxation while filing return of income for the year under consideration. The amount, which the Revenue is talking about, is the amount said to have been receive....

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....el appearing for the writ applicant - assessee and Mr. M. R. Bhatt, the learned Senior Counsel assisted by Mr. Karan Sanghani, the learned counsel appearing for the Revenue. 6. We find merit in the contention raised by Mr. Dave that the reasons assigned by the Assessing Officer for reopening of the assessment for the relevant year are factually incorrect. This is apparent from page : 35 of the ....