DYNACRAFT AIR CONTROLS Vs. SNEHA JOSHI

JUDGEMENT

(1.) Rule, by consent made returnable forthwith. Counsel appearing for the Respondents waives service on behalf of the Respondents. By consent, the Petitions are taken up for hearing and final disposal.

(2.) In the four Writ Petitions that are before the Court, the Petitioner has challenged the validity of notices issued under section 148 of the Income-tax Act, 1961 on 29 March 2012 purporting to re-open the assessments for Assessment Years 2005-06, 2006-07, 2007-08 and 2008-09. The re-opening of assessments for A.Ys. 2005-06 and 2006-07 has taken place beyond the period of four years of the relevant assessment years. The re-opening for A.Ys. 2007-08 and 2008- 09 is within four years. The reasons on the basis of which the assessments are sought to be re-opened are similar.

(3.) The Petitioner is a manufacturer of grills, diffusers, dampers, fire dampers, VAV boxes, VAV terminals, sound attenuators, ducting, false ceilings and electrical lighting fixtures. The Petitioner has a manufacturing facility at Dadra and is registered as a small scale industry.