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TMI Blog2019 (10) TMI 740X X X X Extracts X X X X X X X X Extracts X X X X ..... IB(10) while framing assessment u/s 143(3). As submitted that therefore, the respondent seeks to reopen the assessment merely on the basis of change of opinion. Reference was also made to the sanction given by the superior officer under section 151 to submit that the same has been granted mechanically without application of mind to the facts of the present case and is based merely upon the reasons ..... X X X X Extracts X X X X X X X X Extracts X X X X ..... CIAL CIVIL APPLICATION NO. 17495 of 2019 - - - Dated:- 9-10-2019 - JUSTICE HARSHA DEVANI AND JUSTICE SANGEETA K. VISHEN For The Petitioner (s) : DARSHAN R PATEL (8486) ORAL ORDER ( PER : HONOURABLE MS.JUSTICE HARSHA DEVANI) 1. Mr. Darshan R. Patel, learned advocate for the petitioner invited the attenti ..... X X X X Extracts X X X X X X X X Extracts X X X X ..... sed nonagricultural land bearing Survey Numbers 507, 508, 509, 510 and 523 at Bopal. It was submitted that therefore, the question of obtaining nonagricultural permission thereafter does not arise. It was further pointed out that in the submission it has been duly stated that the local authority in this case was the Town Planning Valuation Department, Ahmedabad and not the Bopal Gram Panchayat. ..... X X X X Extracts X X X X X X X X Extracts X X X X ..... s from the end of the relevant assessment year and hence, in the absence of any failure on part of the petitioner to disclose full and truly all material facts, the assumption of jurisdiction under section 147 of the Act by the respondent Assessing Officer is without authority of law. 4. Having regard to the submissions advanced by the learned advocate for the petitioner, issue no ..... X X X X Extracts X X X X X X X X Extracts X X X X
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