Reopening solely on basis of objection of audit party without application of mind by AO is not valid

HIGH COURT OF GUJARAT Jagat Jayantilal Parikh versus Deputy Commissioner of Income-tax Special Civil Application No. 16062 of 2012 Date of Pronouncement- 28.02.2013 JUDGMENT Ms. Sonia Gokani, J. The petitioner is an individual assessed in the same status for last several years under the Income-tax Act, 1961 (for short, hereinafter referred to as “the Act”). The petitioner herein has challenged the validity of the notice issued under Section-148 of the Act dated 21.11.2011, seeking to reopen the assessment framed by the Assessing Officer on scrutiny under Section-14...