2022 (11) TMI 1268

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.... MR.VARUN K.PATEL WITH MR DEV PATEL FOR THE RESPONDENT ORAL ORDER   (PER : HONOURABLE MS. JUSTICE SONIA GOKANI)   1. The petitioner is before this Court seeking to question the show cause notice issued under Section 148 of the Income Tax Act (hereinafter referred to as 'the Act') which sought to reopen the income tax assessment of the petitioner for the assessment year 2017-18.....

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.... been filed:-   "(a) quash and set aside the impugned notice at ANNEXURE "A " to this petition;   (b) pending the admission, hearing and final disposal of this petition, to stay the implementation and operation of the notice at ANNEXURE "A" to this petition and stay the further proceedings for the Assessment Year 2017-18;   (c) any other and further relief....

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.... matter"   4. The affidavit-in-reply is filed by the respondent no.1 denying each and every averments and urging that the procedure prescribed under the GKN Driveshafts judgment has not been completed, hence, the petition is premature. It also further has contended that all other grounds raised against the reopening of assessment are not sustainable.   5. We have heard learned Seni....