SHYAMLAL RUPCHAND PARWANI Vs. ASSISTANT COMMISSIONER INCOME TAX

JUDGEMENT

(1.) In another set of writ petitions leading being Special Civil Application No. 434 of 2024, arguments were heard on 15/1/2024 and the matter has been kept for orders on 6/2/2024. It is pointed out by Mr. Darshan R. Patel, learned counsel for the petitioners that one writ petition being Special Civil Application No. 436 of 2024 filed by the petitioner herein, namely Shyamlal Rupchand Parwani has been tagged with the aforesaid bunch, though the facts of the said case are somewhat different from the present bunch. It was, therefore, agreed between the parties that since the order has yet not been delivered, Special Civil Application No. 436 of 2024 be also decided with this bunch. We, therefore, direct that the Special Civil Application No. 436 of 2024 be tagged with the present bunch of petitions filed by the same petitioner, namely, Shyamlal Rupchand Parwani arising out of a similar dispute.

(2.) As the issue raised in the present bunch of writ petitions are identical in nature, they have been heard together and are being decided by this common judgement.

(3.) The challenge is to the notice dtd. 9/6/2022 for the Assessment Year 2014-15( in short as A.Y.2014-15") under Sec. 153C of the Income Tax Act, 1961 ( in short as "the Act'1961") as also the order dtd. 2/12/2023 purporting to be the objection disposal order passed by the respondent No.2. The further challenge is to the notice under Sec. 142(1) dtd. 11/12/2023. The prayer is to restrain the respondents from enforcing the compliance of the impugned notice under Sec. 153C dtd. 9/6/2022 for A.Y.2014-15.