The petitioner  filed the writ petition stating that  notice issued under Section 148 of the Act and also an order on objections filed by petitioner for reopening the assessment. There were errors in Column,No.8 and 9 of the Form for re-opening. The sanction granted under Section 151 of the Act was on the basis of incorrect information. The amount mentioned as income originally assessed is Rs.6,01,66,964/-,whereas income originally assessed was Rs.11,11,34,621/-.Allowing the petition the Court held that  the important safeguards provided in Sections 147 and 151 were lightly treated by the Officers. They appear to have taken the duty imposed on them under these provisions as of little importance. The court quashed and set aside the notice issued under Section 148 of the Act. The facts of Writ Petition No.3181 of  2019 and Writ Petition No.3615 of  2019 almost identical Writ Petition No.3023 of 2019 so both petitions were disposed accordingly. The notice was quashed. Referred  Chhugamal Rajpal v. S.P. C haliha & Ors (1971) 79 ITR 603 (SC), German Remedies Ltd v. Dy.CIT (2006) 287 ITR 494 (Bom)(HC)  (WP No. 3023/2019 dt 15-3-2022 (AY.  2012-2013)

Dilip Bhagirathmal Jiwrajka v. DCIT (Bom.)(HC)(UR)

Ashok Bhagirathmal Jiwrajka  v. DCIT (Bom.)(HC)(UR)

Surendra  Bhagirathmal Jiwrajka v. DCIT (Bom.)(HC)(UR)