Writ petition challenging a Section 148 notice reopening assessment for AY 2014-15 as time-barred. Following earlier Division Bench decisions that the ten-year period runs from the end of the relevant assessment year, the court set aside the impugned notice and allowed the petition.
This page shows the compact analysis of this judgement. The full analysis — procedural history, issue-by-issue holdings with ratio and obiter, advocates, and paragraph-level evidence for every claim — is being added to the record in batches and will appear here when this judgement has been through it.
$~97
.....Petitioner
Through: Mr Himanshu S Sinha, Mr Yash Varmani, Mr Utkarsh Mittal and Ms Ishita Sharma, Advocates.
versus
ASSISTANT COMMISSIONER OF INCOME TAX CENTRAL CIRCLE 3, DELHI
.....Respondent Through: Mr Sunil Aggarwal, SSC, Mr Shivansh B Pandya, Mr Viplav Acharya, Ms Priya Sarkar, JSCs and Mr Utkarsh Tiwari, Advocate.
CORAM: HON'BLE MR. JUSTICE VIBHU BAKHRU HON'BLE MR. JUSTICE TEJAS KARIA
O R D E R
% 01.04.2025
This is a digitally signed order. The authenticity of the order can be re-verified from Delhi High Court Order Portal by scanning the QR code shown above. The Order is downloaded from the DHC Server on 04/04/2025 at 14:01:27
Income Tax Central Circle-6, Delhi : Neutral Citation : 2024:DHC:8214DB and Pankaj Jain v. Assistant Commissioner of Income Tax, Central Circle 3, Delhi & Anr. : Neutral Citation: 2025:DHC:157-DB.
VIBHU BAKHRU, J
TEJAS KARIA, J
APRIL 01, 2025 M
Click here to check corrigendum, if any
This is a digitally signed order.
The authenticity of the order can be re-verified from Delhi High Court Order Portal by scanning the QR code shown above. The Order is downloaded from the DHC Server on 04/04/2025 at 14:01:27
1 issue framed by the court
Whether a Section 148 notice seeking to reopen assessment for AY 2014-15 was issued beyond the ten-year limitation period.
Colour shows how this judgement treated each authority
Dinesh Jindal v. Assistant Commissioner of Income Tax, Central Circle 20, Delhi & OthersFollowed¶4
Neutral Citation: 2024: DHC:4554-DB
KAD Housing Private Limited v. Deputy Commissioner of Income Tax Central Circle-6, DelhiFollowed¶4
Neutral Citation : 2024:DHC:8214DB
Pankaj Jain v. Assistant Commissioner of Income Tax, Central Circle 3, Delhi & Anr.Followed¶4
Neutral Citation: 2025:DHC:157-DB
1 provisions across 1 enactments
Canadian Solar International Limited
Assistant Commissioner of Income Tax Central Circle 3, Delhi
Vibhu Bakhru
Tejas Karia
As recorded by the court registry
A petition under Article 226 of the Constitution asking a High Court to issue a writ against the State or a public authority in a civil matter.
Judgements on the same questions, provisions and authorities, from every court
