(1.) Heard learned advocate Mr.S.N.Divatia for the petitioner and learned Senior Standing Counsel Mr.Varun K. Patel with learned advocate Mr.Dev Patel for the respondent no.1.
(2.) Issue Rule returnable forthwith. Learned Senior Standing Counsel Mr.Varun K. Patel waives service of notice of rule on behalf of respondent no.1. Having regard to the controversy in narrow compass, with the consent of learned advocates appearing for the respective parties, the matter is taken up for final hearing.
(3.) By this petition under Article 226 of the Constitution of India the petitioner has challenged notice dtd. 31/3/2019 issued by the respondent under Sec. 148 of the Income Tax Act, 1961 (for short "the Act")for the assessment year 2012-13 proposing to reopen the assessment.