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TMI Blog2025 (1) TMI 1299X X X X Extracts X X X X X X X X Extracts X X X X ..... s Nupur D Shah (10233). For the Respondent(s) No. 1: Ms Maithili D Mehta (3206). ORAL ORDER (PER : HONOURABLE MR. JUSTICE BHARGAV D. KARIA) 1. Heard learned advocate Ms. Nupur D. Shah for the petitioner and learned Senior Standing Counsel Ms. Maithili D. Mehta for the respondent. 2. Rule returnable forthwith. Learned Senior Standing Counsel Ms. Maithili D. Mehta waives service ..... X X X X Extracts X X X X X X X X Extracts X X X X ..... has purchased immovable property for Rs.6,00,00,000/- during the year under consideration. However, the return income does not commensurate with such huge investment made by the assessee. 3. On analysis of the information, it is seen that the assessee has purchased immovable property for Rs.6,00,00,000/- during the year under consideration. However, the return income does not commensurate with ..... X X X X Extracts X X X X X X X X Extracts X X X X ..... - is required to be added to the total income to the assessee." 6. The brief facts of the case are that: 6.1 The petitioner filed the return of income for the year 2016- 17 through electronic media on 25.07.2016 declaring total income of Rs.13,98,440/- for A.Y. 2016-17. Thereafter, the notice under section 143(2) of the Act dated 05.07.2017 was issued calling upon the petitioner for limited scr ..... X X X X Extracts X X X X X X X X Extracts X X X X ..... f capital gain/loss and the copy of sale deed for consideration of Rs. 6,00,00,000/-. 6.4 The petitioner submitted all the details with regard to immovable properties purchased during the year under consideration by replies dated 13.12.2018 and 19.12.2018. 6.5 It was submitted by the petitioner in the reply that the property worth Rs. 6,00,00,000/- was purchased from the gift received by her son ..... X X X X Extracts X X X X X X X X Extracts X X X X ..... ng but a mere change of opinion by the respondent Assessing Officer to reopen assessment ignoring the details and the replies filed by the petitioner available on record. 8. In view of the above facts, the petition succeeds and is accordingly allowed. The impugned notice dated 31.03.2021 issued under section 148 of the Act for reopening of the Assessment Year 2016-17 is hereby quashed and set asi ..... X X X X Extracts X X X X X X X X Extracts X X X X
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