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TMI Blog2025 (4) TMI 351X X X X Extracts X X X X X X X X Extracts X X X X ..... nan For the Petitioner in all W.Ps : Mr. S. Sathiyanarayanan For the Respondents in all W.Ps : Mr. S. Rajasekar, Standing Counsel COMMON ORDER Heard Mr.S.Sathiyanarayanan, learned counsel for the petitioner and Mr.S.Rajasekar, learned Standing Counsel for the respondents. 2. The present writ petition has been filed by the petitioner challenging the Notices dated 30.03.2021 bearing DIN:ITBA/AS ..... X X X X Extracts X X X X X X X X Extracts X X X X ..... 1031906165(1) 2017-18 3 6405/2022 31.03.2021 & DIN: ITBA/AST/S/148/2020-21/1032004635(1) 2013-14 4. The assessment were completed and Assessment Orders were also passed for the respective assessment years as detailed below: Sl.No. Writ Petition No. Date of the Assessment Order Assessment Year 1 6396/2022 29.01.2019 2015-16 2 6401/2022 10.12.2019 2017-18 3 6405/2022 23.03.20 ..... X X X X Extracts X X X X X X X X Extracts X X X X ..... (SC) as well as the guidelines laid down by the Gujarat High Court in the case of Sahkari Khand Udyog Mandal Ltd. Vs. Assistant Commissioner of Income Tax (Special Civil Application No.3955 of 2014) vide separate speaking orders dated 15.02.2022, 24.01.2022 & 14.02.2022 respectively. 7. It is seen that W.P.No.6390 of 2022 was also filed along with the present writ petitions. When all these writ p ..... X X X X Extracts X X X X X X X X Extracts X X X X ..... 4, this Court has dismissed W.P.No.6390 of 2022 with the following observation: "12. Prima facie it appears that the reopening of the assessment was justified. It is noticed that the reasons stated in the letter dated 19.08.2021 also brings out the same. Therefore, there is no merits in challenge to impugned notice dated 30.03.2021 or the speaking order dated 24.01.2022, as the petitioner has no ..... X X X X Extracts X X X X X X X X Extracts X X X X ..... t the same were issued without jurisdiction, these writ petitions would have been entertained on merits. Therefore, these writ petitions are liable to be dismissed. 11. Accordingly, these Writ Petitions are dismissed. It is open for the concerned Adjudicating Authority to decide the re-opening of assessment of the petitioner company for the Assessment Years 2015-16, 2017-18 & 2013-14. No costs. C ..... X X X X Extracts X X X X X X X X Extracts X X X X
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