2022 (12) TMI 117

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.... MR.VARUN K.PATEL FOR THE RESPONDENT ORDER PER : HONOURABLE MS. JUSTICE SONIA GOKANI 1. The petition under Article 226 of the Constitution of India challenges the notice dated 30.03.2021 issued by the respondent under Section 148 of the Income Tax Act (hereinafter referred to as 'the Act') seeking to reopen the income tax assessment for the assessment year 2015-16. 2. The petitioner is....

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....e following prayers:- "(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 2015-16; (c) any other and further relief deemed just ....

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.... Patel with learned Standing Counsel Mr. Dev Patel for the department. 5. According to learned Senior Advocate Mr. Hemani, it is not unknown to this Court that pending the petition, objections can be directed to be disposed of as it is a group of the matters where there is hardly any possibility of the respondent taking any other stand while disposing of objections. This was resisted by the oth....