SCA/11005/2025

Judgment text excerpt

NEUTRAL CITATION C/SCA/11005/2025 JUDGMENT DATED: 08/06/2026 2026:GUJHC:34851-DB IN THE HIGH COURT OF GUJARAT AT AHMEDABAD R/SPECIAL CIVIL APPLICATION NO. 11005 of 2025 FOR APPROVAL AND SIGNATURE: HONOURABLE MR. JUSTICE A.S. SUPEHIA and HONOURABLE MS. JUSTICE VAIBHAVI D. NANAVATI ==================================== Approved for Reporting Yes No ✔ ==================================== PANDESARA INFRASTRUCTURE LIMITED Versus THE ASSISTANT COMMISSIONER OF INCOME TAX CENTRAL CIRCLE - 2(1)(1) SURAT ==================================== Appearance: MR. TUSHAR HEMANI Senior Counsel assisted by MS.VAIBHAVI K PARIKH(3238) for the Petitioner(s) No. 1 MR KARAN G SANGHANI(7945) for the Respondent(s) No. 1 ==================================== CORAM:HONOURABLE MR. JUSTICE A.S. SUPEHIA and HONOURABLE MS. JUSTICE VAIBHAVI D. NANAVATI Date : 08/06/2026 ORAL JUDGMENT (PER : HONOURABLE MR. JUSTICE A.S. SUPEHIA) 1. RULE. Learned Senior Standing Counsel Mr. Karan G. Sanghani waives service of notice of rule on behalf of the respondent. Page 1 of 15 Uploaded by () on Downloaded on : Tue Jun 30 23:21:15 IST 2026 NEUTRAL CITATION C/SCA/11005/2025 JUDGMENT DATED: 08/06/2026 2026:GUJHC:34851-DB 2. Since a short issue is involved, with the consent of the learned counsel appearing for the respective parties, the matter is taken up for final hearing. 3. By way of the present petition under Article 226 of the Constitution of India, the petitioner challenges the Notice dated 28/06/2025 issued under Section 148 of the Income Tax Act, 1961 (hereinafter referred to as ‘the Act’) and the Order dated 28/06/2025 issued under Section 148A (3) of the Act. 4. The brief facts of the case are that, the petitioner is engaged in providing the services to the cluster of industries in Pandesara, Surat in the field o