Writ petition challenging a reassessment notice under Section 148 of the Income Tax Act. The court held the notice was not without jurisdiction and the Assessing Officer had a reasonable basis to proceed, leaving contentions to be raised before the AO.
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.
$~10
.....Petitioner
Through: Mr. Kaushik and Mr. Ram Naresh, Advocates.
versus
UNION OF INDIA THROUGH SECRETARY OF FINANCE & ANR. .....Respondents
Through: Mr. Anil Panwar, SPC with Ms. Rakshita Goyal, Mr. Nikhil Goel and Mr. Sahej Sawhney, Advocates for R- 1/UOI.
Mr. Gaurav Gupta, SSC with Mr. Shivendra Singh, JSC, Mr. Yojit Pareek, JSC and Ms. Aryama Singh Rajput, Advocate for R-2/Income Tax Dept.
CORAM: HON'BLE MR. JUSTICE DINESH MEHTA HON'BLE MR. JUSTICE RAJNEESH KUMAR GUPTA
O R D E R % 08.07.2026
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 10/07/2026 at 11:49:11
shows that the Assessing Officer (hereinafter referred to as ‘AO’) has a reasonable basis to proceed against the petitioner. The arguments which learned Counsel for the petitioner has advanced before us, may or may not have a bearing on the quantum of addition (if made), but by this reason itself, the notice issued by the AO cannot be alleged to be without jurisdiction so as to warrant interference by us.
DINESH MEHTA, J.
RAJNEESH KUMAR GUPTA, J.
JULY 8, 2026/ MR
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 10/07/2026 at 11:49:11
1 issue framed by the court
Whether the notice under Section 148 of the Income Tax Act, 1961 dated 29.06.2025 was without jurisdiction and liable to be quashed.
2 provisions across 1 enactments
Manchanda Herbal Products Private Limited
Union of India through Secretary of Finance
Income Tax Dept.
Dinesh Mehta
Rajneesh Kumar Gupta
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
