Suzlon Global Services Limited vs. Assistant Commissioner Of Income Tax

IN THE HIGH COURT OF GUJARAT AT AHMEDABAD

R/SPECIAL CIVIL APPLICATION NO. 9909 of 2022 With R/SPECIAL CIVIL APPLICATION NO. 1842 of 2023 With R/SPECIAL CIVIL APPLICATION NO. 553 of 2023 With R/SPECIAL CIVIL APPLICATION NO. 645 of 2023 With R/SPECIAL CIVIL APPLICATION NO. 434 of 2023 With R/SPECIAL CIVIL APPLICATION NO. 777 of 2023 With R/SPECIAL CIVIL APPLICATION NO. 1241 of 2023 With R/SPECIAL CIVIL APPLICATION NO. 1242 of 2023 With R/SPECIAL CIVIL APPLICATION NO. 1226 of 2023 With R/SPECIAL CIVIL APPLICATION NO. 1255 of 2023 With R/SPECIAL CIVIL APPLICATION NO. 1243 of 2023 With R/SPECIAL CIVIL APPLICATION NO. 1575 of 2024 With R/SPECIAL CIVIL APPLICATION NO. 2065 of 2023 With R/SPECIAL CIVIL APPLICATION NO. 2450 of 2024 With R/SPECIAL CIVIL APPLICATION NO. 2974 of 2023 With R/SPECIAL CIVIL APPLICATION NO. 5171 of 2023 With R/SPECIAL CIVIL APPLICATION NO. 4296 of 2024 With R/SPECIAL CIVIL APPLICATION NO. 5373 of 2023 With R/SPECIAL CIVIL APPLICATION NO. 6974 of 2023 With R/SPECIAL CIVIL APPLICATION NO. 7231 of 2023 With R/SPECIAL CIVIL APPLICATION NO. 6485 of 2023 With R/SPECIAL CIVIL APPLICATION NO. 6823 of 2023

With R/SPECIAL CIVIL APPLICATION NO. 7766 of 2023 With R/SPECIAL CIVIL APPLICATION NO. 7481 of 2022 With R/SPECIAL CIVIL APPLICATION NO. 6975 of 2023 With R/SPECIAL CIVIL APPLICATION NO. 9609 of 2023 With R/SPECIAL CIVIL APPLICATION NO. 7660 of 2022 With R/SPECIAL CIVIL APPLICATION NO. 7632 of 2022 With R/SPECIAL CIVIL APPLICATION NO. 7616 of 2022 With R/SPECIAL CIVIL APPLICATION NO. 7988 of 2022 With R/SPECIAL CIVIL APPLICATION NO. 7382 of 2023 With R/SPECIAL CIVIL APPLICATION NO. 7367 of 2023 With R/SPECIAL CIVIL APPLICATION NO. 7227 of 2023 With R/SPECIAL CIVIL APPLICATION NO. 8206 of 2022 With R/SPECIAL CIVIL APPLICATION NO. 8004 of 2022 With R/SPECIAL CIVIL APPLICATION NO. 8201 of 2022 With R/SPECIAL CIVIL APPLICATION NO. 7469 of 2023 With R/SPECIAL CIVIL APPLICATION NO. 7428 of 2023 With R/SPECIAL CIVIL APPLICATION NO. 7480 of 2023 With R/SPECIAL CIVIL APPLICATION NO. 8006 of 2022 With R/SPECIAL CIVIL APPLICATION NO. 8202 of 2022 With R/SPECIAL CIVIL APPLICATION NO. 8032 of 2022 With R/SPECIAL CIVIL APPLICATION NO. 8110 of 2022 With R/SPECIAL CIVIL APPLICATION NO. 8231 of 2022 With R/SPECIAL CIVIL APPLICATION NO. 7503 of 2023 With

R/SPECIAL CIVIL APPLICATION NO. 10867 of 2023 With R/SPECIAL CIVIL APPLICATION NO. 11341 of 2023 With R/SPECIAL CIVIL APPLICATION NO. 8211 of 2022 With R/SPECIAL CIVIL APPLICATION NO. 8519 of 2022 With R/SPECIAL CIVIL APPLICATION NO. 6587 of 2024 With R/SPECIAL CIVIL APPLICATION NO. 8529 of 2022 With R/SPECIAL CIVIL APPLICATION NO. 8645 of 2022 With R/SPECIAL CIVIL APPLICATION NO. 8585 of 2022 With R/SPECIAL CIVIL APPLICATION NO. 8582 of 2022 With R/SPECIAL CIVIL APPLICATION NO. 8583 of 2022 With R/SPECIAL CIVIL APPLICATION NO. 8598 of 2022 With R/SPECIAL CIVIL APPLICATION NO. 8599 of 2022 With R/SPECIAL CIVIL APPLICATION NO. 15101 of 2022 With R/SPECIAL CIVIL APPLICATION NO. 15322 of 2022 With R/SPECIAL CIVIL APPLICATION NO. 8086 of 2023 With R/SPECIAL CIVIL APPLICATION NO. 6920 of 2024 With R/SPECIAL CIVIL APPLICATION NO. 10015 of 2022 With R/SPECIAL CIVIL APPLICATION NO. 9986 of 2022 With R/SPECIAL CIVIL APPLICATION NO. 7088 of 2024 With R/SPECIAL CIVIL APPLICATION NO. 6864 of 2024 With R/SPECIAL CIVIL APPLICATION NO. 7965 of 2023 With R/SPECIAL CIVIL APPLICATION NO. 9667 of 2024 With R/SPECIAL CIVIL APPLICATION NO. 9916 of 2023 With R/SPECIAL CIVIL APPLICATION NO. 10531 of 2023

With R/SPECIAL CIVIL APPLICATION NO. 7105 of 2024 With R/SPECIAL CIVIL APPLICATION NO. 6941 of 2024 With R/SPECIAL CIVIL APPLICATION NO. 8697 of 2023 With R/SPECIAL CIVIL APPLICATION NO. 8974 of 2023 With R/SPECIAL CIVIL APPLICATION NO. 9724 of 2022 With R/SPECIAL CIVIL APPLICATION NO. 7407 of 2024 With R/SPECIAL CIVIL APPLICATION NO. 7300 of 2024 With R/SPECIAL CIVIL APPLICATION NO. 8975 of 2023 With R/SPECIAL CIVIL APPLICATION NO. 7362 of 2024 With R/SPECIAL CIVIL APPLICATION NO. 10837 of 2023 With R/SPECIAL CIVIL APPLICATION NO. 10815 of 2023 With R/SPECIAL CIVIL APPLICATION NO. 9008 of 2023 With R/SPECIAL CIVIL APPLICATION NO. 10465 of 2023 With R/SPECIAL CIVIL APPLICATION NO. 10856 of 2023 With R/SPECIAL CIVIL APPLICATION NO. 10154 of 2023 With R/SPECIAL CIVIL APPLICATION NO. 9068 of 2023 With R/SPECIAL CIVIL APPLICATION NO. 10229 of 2023 With R/SPECIAL CIVIL APPLICATION NO. 12314 of 2023 With R/SPECIAL CIVIL APPLICATION NO. 11274 of 2023 With R/SPECIAL CIVIL APPLICATION NO. 10154 of 2024 With R/SPECIAL CIVIL APPLICATION NO. 9066 of 2024 With R/SPECIAL CIVIL APPLICATION NO. 9080 of 2024 With R/SPECIAL CIVIL APPLICATION NO. 9122 of 2024 With

R/SPECIAL CIVIL APPLICATION NO. 9025 of 2024 With R/SPECIAL CIVIL APPLICATION NO. 8284 of 2024 With R/SPECIAL CIVIL APPLICATION NO. 9197 of 2024 With R/SPECIAL CIVIL APPLICATION NO. 8683 of 2024 With R/SPECIAL CIVIL APPLICATION NO. 8947 of 2024 With R/SPECIAL CIVIL APPLICATION NO. 10279 of 2022 With R/SPECIAL CIVIL APPLICATION NO. 10264 of 2022 With R/SPECIAL CIVIL APPLICATION NO. 10648 of 2022 With R/SPECIAL CIVIL APPLICATION NO. 8758 of 2024 With R/SPECIAL CIVIL APPLICATION NO. 8997 of 2024 With R/SPECIAL CIVIL APPLICATION NO. 10619 of 2022 With R/SPECIAL CIVIL APPLICATION NO. 15315 of 2022 With R/SPECIAL CIVIL APPLICATION NO. 8857 of 2024 With R/SPECIAL CIVIL APPLICATION NO. 11319 of 2023 With R/SPECIAL CIVIL APPLICATION NO. 11324 of 2023 With R/SPECIAL CIVIL APPLICATION NO. 13384 of 2022 With R/SPECIAL CIVIL APPLICATION NO. 13806 of 2022 With R/SPECIAL CIVIL APPLICATION NO. 11325 of 2023 With R/SPECIAL CIVIL APPLICATION NO. 11130 of 2023 With R/SPECIAL CIVIL APPLICATION NO. 9192 of 2024 With R/SPECIAL CIVIL APPLICATION NO. 13649 of 2022 With R/SPECIAL CIVIL APPLICATION NO. 11208 of 2023 With R/SPECIAL CIVIL APPLICATION NO. 9240 of 2024 With R/SPECIAL CIVIL APPLICATION NO. 12131 of 2023

With R/SPECIAL CIVIL APPLICATION NO. 9288 of 2024 With R/SPECIAL CIVIL APPLICATION NO. 11617 of 2023 With R/SPECIAL CIVIL APPLICATION NO. 9415 of 2024 With R/SPECIAL CIVIL APPLICATION NO. 9810 of 2024 With R/SPECIAL CIVIL APPLICATION NO. 11334 of 2023 With R/SPECIAL CIVIL APPLICATION NO. 12106 of 2023 With R/SPECIAL CIVIL APPLICATION NO. 9507 of 2024 With R/SPECIAL CIVIL APPLICATION NO. 10222 of 2024 With R/SPECIAL CIVIL APPLICATION NO. 9622 of 2024 With R/SPECIAL CIVIL APPLICATION NO. 12410 of 2023 With R/SPECIAL CIVIL APPLICATION NO. 9615 of 2024 With R/SPECIAL CIVIL APPLICATION NO. 9621 of 2024 With R/SPECIAL CIVIL APPLICATION NO. 10121 of 2024 With R/SPECIAL CIVIL APPLICATION NO. 9674 of 2024 With R/SPECIAL CIVIL APPLICATION NO. 9731 of 2024 With R/SPECIAL CIVIL APPLICATION NO. 9738 of 2024 With R/SPECIAL CIVIL APPLICATION NO. 12418 of 2023 With R/SPECIAL CIVIL APPLICATION NO. 12690 of 2023 With R/SPECIAL CIVIL APPLICATION NO. 10220 of 2024 With R/SPECIAL CIVIL APPLICATION NO. 10060 of 2024 With R/SPECIAL CIVIL APPLICATION NO. 10143 of 2024 With R/SPECIAL CIVIL APPLICATION NO. 22351 of 2022 With R/SPECIAL CIVIL APPLICATION NO. 10698 of 2024 With

R/SPECIAL CIVIL APPLICATION NO. 10808 of 2024 With R/SPECIAL CIVIL APPLICATION NO. 10597 of 2024 With R/SPECIAL CIVIL APPLICATION NO. 10568 of 2024 With R/SPECIAL CIVIL APPLICATION NO. 10418 of 2024 With R/SPECIAL CIVIL APPLICATION NO. 14544 of 2022 With R/SPECIAL CIVIL APPLICATION NO. 15020 of 2023 With R/SPECIAL CIVIL APPLICATION NO. 15035 of 2023 With R/SPECIAL CIVIL APPLICATION NO. 10522 of 2024 With R/SPECIAL CIVIL APPLICATION NO. 10891 of 2024 With R/SPECIAL CIVIL APPLICATION NO. 10806 of 2024 With R/SPECIAL CIVIL APPLICATION NO. 10797 of 2024 With R/SPECIAL CIVIL APPLICATION NO. 11010 of 2024 With R/SPECIAL CIVIL APPLICATION NO. 10734 of 2024 With R/SPECIAL CIVIL APPLICATION NO. 14934 of 2022 With R/SPECIAL CIVIL APPLICATION NO. 11015 of 2024 With R/SPECIAL CIVIL APPLICATION NO. 23328 of 2022 With R/SPECIAL CIVIL APPLICATION NO. 14167 of 2023 With R/SPECIAL CIVIL APPLICATION NO. 11447 of 2024 With R/SPECIAL CIVIL APPLICATION NO. 11295 of 2024 With R/SPECIAL CIVIL APPLICATION NO. 11311 of 2024 With R/SPECIAL CIVIL APPLICATION NO. 11331 of 2024 With R/SPECIAL CIVIL APPLICATION NO. 16108 of 2023 With R/SPECIAL CIVIL APPLICATION NO. 11633 of 2024 With R/SPECIAL CIVIL APPLICATION NO. 12160 of 2024

With
R/SPECIAL CIVIL APPLICATION NO. 17238 of 2022<br>With
R/SPECIAL CIVIL APPLICATION NO. 17039 of 2022<br>With
R/SPECIAL CIVIL APPLICATION NO. 17328 of 2022
With<br>R/SPECIAL CIVIL APPLICATION NO. 12296 of 2024
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With<br>R/SPECIAL CIVIL APPLICATION NO. 18789 of 2022
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With<br>R/SPECIAL CIVIL APPLICATION NO. 17704 of 2022
With<br>R/SPECIAL CIVIL APPLICATION NO. 18007 of 2022
With<br>R/SPECIAL CIVIL APPLICATION NO. 17816 of 2022
With<br>R/SPECIAL CIVIL APPLICATION NO. 17856 of 2022
With
R/SPECIAL CIVIL APPLICATION NO. 18466 of 2022<br>With
R/SPECIAL CIVIL APPLICATION NO. 12783 of 2024<br>With
R/SPECIAL CIVIL APPLICATION NO. 12668 of 2024<br>With
R/SPECIAL CIVIL APPLICATION NO. 19457 of 2022<br>With
R/SPECIAL CIVIL APPLICATION NO. 12767 of 2024<br>With
R/SPECIAL CIVIL APPLICATION NO. 13452 of 2024<br>With
R/SPECIAL CIVIL APPLICATION NO. 13479 of 2024<br>With
R/SPECIAL CIVIL APPLICATION NO. 13019 of 2024<br>With
R/SPECIAL CIVIL APPLICATION NO. 12994 of 2024
With<br>R/SPECIAL CIVIL APPLICATION NO. 13005 of 2024
With<br>R/SPECIAL CIVIL APPLICATION NO. 13416 of 2024<br>With

R/SPECIAL CIVIL APPLICATION NO. 12999 of 2024 With R/SPECIAL CIVIL APPLICATION NO. 12991 of 2024 With R/SPECIAL CIVIL APPLICATION NO. 13946 of 2024 With R/SPECIAL CIVIL APPLICATION NO. 13234 of 2024 With R/SPECIAL CIVIL APPLICATION NO. 13315 of 2024 With R/SPECIAL CIVIL APPLICATION NO. 13142 of 2024 With R/SPECIAL CIVIL APPLICATION NO. 13094 of 2024 With R/SPECIAL CIVIL APPLICATION NO. 13171 of 2024 With R/SPECIAL CIVIL APPLICATION NO. 13265 of 2024 With R/SPECIAL CIVIL APPLICATION NO. 18885 of 2022 With R/SPECIAL CIVIL APPLICATION NO. 20749 of 2022 With R/SPECIAL CIVIL APPLICATION NO. 21199 of 2022 With R/SPECIAL CIVIL APPLICATION NO. 13250 of 2024 With R/SPECIAL CIVIL APPLICATION NO. 13582 of 2024 With R/SPECIAL CIVIL APPLICATION NO. 13325 of 2024 With R/SPECIAL CIVIL APPLICATION NO. 13823 of 2024 With R/SPECIAL CIVIL APPLICATION NO. 19800 of 2022 With R/SPECIAL CIVIL APPLICATION NO. 13443 of 2024 With R/SPECIAL CIVIL APPLICATION NO. 14296 of 2024 With R/SPECIAL CIVIL APPLICATION NO. 21375 of 2022 With R/SPECIAL CIVIL APPLICATION NO. 19556 of 2023 With R/SPECIAL CIVIL APPLICATION NO. 19692 of 2023 With R/SPECIAL CIVIL APPLICATION NO. 17348 of 2023 With R/SPECIAL CIVIL APPLICATION NO. 13922 of 2024

With
R/SPECIAL CIVIL APPLICATION NO. 13902 of 2024<br>With
R/SPECIAL CIVIL APPLICATION NO. 13606 of 2024<br>With
R/SPECIAL CIVIL APPLICATION NO. 13609 of 2024
With<br>R/SPECIAL CIVIL APPLICATION NO. 13525 of 2024
With<br>R/SPECIAL CIVIL APPLICATION NO. 13755 of 2024
With<br>R/SPECIAL CIVIL APPLICATION NO. 13701 of 2024
With<br>R/SPECIAL CIVIL APPLICATION NO. 13583 of 2024
With<br>R/SPECIAL CIVIL APPLICATION NO. 13889 of 2024
With<br>R/SPECIAL CIVIL APPLICATION NO. 14579 of 2024
With
R/SPECIAL CIVIL APPLICATION NO. 13947 of 2024<br>With
R/SPECIAL CIVIL APPLICATION NO. 13942 of 2024<br>With
R/SPECIAL CIVIL APPLICATION NO. 13918 of 2024<br>With
R/SPECIAL CIVIL APPLICATION NO. 14022 of 2024<br>With
R/SPECIAL CIVIL APPLICATION NO. 13828 of 2024<br>With
R/SPECIAL CIVIL APPLICATION NO. 13763 of 2024<br>With
R/SPECIAL CIVIL APPLICATION NO. 14069 of 2024
With<br>R/SPECIAL CIVIL APPLICATION NO. 13961 of 2024
With<br>R/SPECIAL CIVIL APPLICATION NO. 13848 of 2024
With<br>R/SPECIAL CIVIL APPLICATION NO. 14092 of 2024
With<br>R/SPECIAL CIVIL APPLICATION NO. 17347 of 2023
With<br>R/SPECIAL CIVIL APPLICATION NO. 14698 of 2024
With<br>R/SPECIAL CIVIL APPLICATION NO. 20207 of 2022
With<br>R/SPECIAL CIVIL APPLICATION NO. 13832 of 2024
With

R/SPECIAL CIVIL APPLICATION NO. 22394 of 2022 With R/SPECIAL CIVIL APPLICATION NO. 13896 of 2024 With R/SPECIAL CIVIL APPLICATION NO. 13864 of 2024 With R/SPECIAL CIVIL APPLICATION NO. 13862 of 2024 With R/SPECIAL CIVIL APPLICATION NO. 14189 of 2024 With R/SPECIAL CIVIL APPLICATION NO. 14496 of 2024 With R/SPECIAL CIVIL APPLICATION NO. 14024 of 2024 With R/SPECIAL CIVIL APPLICATION NO. 21373 of 2022 With R/SPECIAL CIVIL APPLICATION NO. 22395 of 2022 With R/SPECIAL CIVIL APPLICATION NO. 14237 of 2024 With R/SPECIAL CIVIL APPLICATION NO. 14364 of 2024 With R/SPECIAL CIVIL APPLICATION NO. 21671 of 2022 With R/SPECIAL CIVIL APPLICATION NO. 14292 of 2024 With R/SPECIAL CIVIL APPLICATION NO. 14446 of 2024 With R/SPECIAL CIVIL APPLICATION NO. 14404 of 2024 With R/SPECIAL CIVIL APPLICATION NO. 14749 of 2024 With R/SPECIAL CIVIL APPLICATION NO. 21412 of 2022 With R/SPECIAL CIVIL APPLICATION NO. 21285 of 2022 With R/SPECIAL CIVIL APPLICATION NO. 14810 of 2024 With R/SPECIAL CIVIL APPLICATION NO. 21464 of 2022 With R/SPECIAL CIVIL APPLICATION NO. 14355 of 2024 With R/SPECIAL CIVIL APPLICATION NO. 14368 of 2024 With R/SPECIAL CIVIL APPLICATION NO. 14365 of 2024 With R/SPECIAL CIVIL APPLICATION NO. 15088 of 2024

With
R/SPECIAL CIVIL APPLICATION NO. 14801 of 2024<br>With
R/SPECIAL CIVIL APPLICATION NO. 14611 of 2024<br>With
R/SPECIAL CIVIL APPLICATION NO. 14612 of 2024<br>With
R/SPECIAL CIVIL APPLICATION NO. 15151 of 2024
With<br>R/SPECIAL CIVIL APPLICATION NO. 14771 of 2024
With<br>R/SPECIAL CIVIL APPLICATION NO. 18444 of 2023
With<br>R/SPECIAL CIVIL APPLICATION NO. 23015 of 2022
With<br>R/SPECIAL CIVIL APPLICATION NO. 22945 of 2022
With<br>R/SPECIAL CIVIL APPLICATION NO. 15430 of 2024
With<br>R/SPECIAL CIVIL APPLICATION NO. 15236 of 2024
With<br>R/SPECIAL CIVIL APPLICATION NO. 18609 of 2023
With<br>R/SPECIAL CIVIL APPLICATION NO. 15871 of 2024
With<br>R/SPECIAL CIVIL APPLICATION NO. 1392 of 2024
With
R/SPECIAL CIVIL APPLICATION NO. 22421 of 2022<br>With
R/SPECIAL CIVIL APPLICATION NO. 16496 of 2024<br>With
R/SPECIAL CIVIL APPLICATION NO. 16748 of 2024<br>With
R/SPECIAL CIVIL APPLICATION NO. 15526 of 2024<br>With
R/SPECIAL CIVIL APPLICATION NO. 15404 of 2024<br>With
R/SPECIAL CIVIL APPLICATION NO. 24688 of 2022<br>With
R/SPECIAL CIVIL APPLICATION NO. 24683 of 2022<br>With
R/SPECIAL CIVIL APPLICATION NO. 15703 of 2024<br>With
R/SPECIAL CIVIL APPLICATION NO. 15735 of 2024<br>With
R/SPECIAL CIVIL APPLICATION NO. 15669 of 2024<br>With

Page 12 of 15

R/SPECIAL CIVIL APPLICATION NO. 19466 of 2023 With R/SPECIAL CIVIL APPLICATION NO. 16300 of 2024 With R/SPECIAL CIVIL APPLICATION NO. 16316 of 2024 With R/SPECIAL CIVIL APPLICATION NO. 15665 of 2024 With R/SPECIAL CIVIL APPLICATION NO. 23918 of 2022 With R/SPECIAL CIVIL APPLICATION NO. 23894 of 2022 With R/SPECIAL CIVIL APPLICATION NO. 23924 of 2022 With R/SPECIAL CIVIL APPLICATION NO. 23896 of 2022 With R/SPECIAL CIVIL APPLICATION NO. 24690 of 2022 With R/SPECIAL CIVIL APPLICATION NO. 25459 of 2022 With R/SPECIAL CIVIL APPLICATION NO. 25457 of 2022 With R/SPECIAL CIVIL APPLICATION NO. 25456 of 2022 With R/SPECIAL CIVIL APPLICATION NO. 16409 of 2024 With R/SPECIAL CIVIL APPLICATION NO. 16528 of 2024 With R/SPECIAL CIVIL APPLICATION NO. 16582 of 2024 With R/SPECIAL CIVIL APPLICATION NO. 16381 of 2024 With R/SPECIAL CIVIL APPLICATION NO. 25472 of 2022 With R/SPECIAL CIVIL APPLICATION NO. 16648 of 2024 With R/SPECIAL CIVIL APPLICATION NO. 16535 of 2024 With R/SPECIAL CIVIL APPLICATION NO. 16641 of 2024 With R/SPECIAL CIVIL APPLICATION NO. 16812 of 2024 With R/SPECIAL CIVIL APPLICATION NO. 16639 of 2024 With R/SPECIAL CIVIL APPLICATION NO. 16654 of 2024 With R/SPECIAL CIVIL APPLICATION NO. 17018 of 2024

With R/SPECIAL CIVIL APPLICATION NO. 16835 of 2024 With R/SPECIAL CIVIL APPLICATION NO. 21049 of 2023 With R/SPECIAL CIVIL APPLICATION NO. 26021 of 2022 With R/SPECIAL CIVIL APPLICATION NO. 26022 of 2022 With R/SPECIAL CIVIL APPLICATION NO. 16933 of 2024 With R/SPECIAL CIVIL APPLICATION NO. 26201 of 2022 With R/SPECIAL CIVIL APPLICATION NO. 26249 of 2022 With R/SPECIAL CIVIL APPLICATION NO. 26199 of 2022 With R/SPECIAL CIVIL APPLICATION NO. 17108 of 2024 With R/SPECIAL CIVIL APPLICATION NO. 17263 of 2024 With R/SPECIAL CIVIL APPLICATION NO. 214 of 2023 ========================================================== SNEHDHAM TRUST

Versus ASSISTANT COMMISSIONER OF INCOME TAX, CENTRAL CIRCLE 2(2), AHMEDABAD ==========================================================

Appearance: MR B S SOPARKAR(6851) for the Petitioner(s) No. 1 DS AFF.NOT FILED (R) for the Respondent(s) No. 1 MR.VARUN K.PATEL(3802) for the Respondent(s) No. 1 ==========================================================

CORAM:HONOURABLE MR. JUSTICE BHARGAV D. KARIA and HONOURABLE MR.JUSTICE D.N.RAY

Date : 20/01/2025 ORAL ORDER (PER : HONOURABLE MR. JUSTICE BHARGAV D. KARIA)

At the joint request of learned advocates for the respective

parties to await the outcome of the matters pending before the

Hon'ble Supreme Court regarding the issue of jurisdiction of the Jurisdictional Assessing Officer and Faceless Assessment Officer for issuance of the notice for reopening as per the the Scheme framed under section 151A of the Income Tax Act,1961, Stand over to 24.03.2025.

(BHARGAV D. KARIA, J)

JYOTI V. JANI

(D.N.RAY,J)

Original copy of this order has been signed by the Hon'ble Judges. Digitally signed by: JYOTIBEN VINODKUMAR JANI(HC00213), PRINCIPAL PRIVATE SECRETARY, at High Court of Gujarat on 22/01/2025 18:02:33