(1.) Present petition is preferred under Article 226 of the Constitution of India seeking to challenge the notice of reopening under sec. 148 of the Income Tax Act, 1961 ('the IT Act ' hereinafter) dtd. 26/7/2022 and the impugned order passed under sec. 148A(d) of the selfsame date with the following prayers:
(2.) We have heard the learned advocate, Mr.Tej Shah appearing for the petitioner and made the Urgent Notice, returnable forthwith. Learned senior standing counsel, Mr.Varun Patel has been requested to appear for the respondent-Department.
(3.) In wake of the decision of this Court in case of Keenara Industries Private Limited Versus The Income Tax Officer, Ward 1(1)(3), Surat, passed in Special Civil Application No.17321 of 2022 and allied maters, this being the Assessment Year 2014-15 on the ground of the limitation, this petition deserves to be allowed.