ANKIT KHANDELWAL vs INCOME TAX OFFICER & ORS.

Judgment text excerpt

$~100 * IN THE HIGH COURT OF DELHI AT NEW DELHI % Date of Decision: 01.04.2025 + W.P.(C) 297/2023 and CM APPL. 18287/2025 ANKIT KHANDELWAL .....Petitioner Through: Mr Rohit Jain and Mr Samarth Chaudhari, Advocates. versus INCOME TAX OFFICER & ORS. .....Respondents Through: Mr Gaurav Gupta, senior standing counsel with Mr Shivendra Singh and Mr Yojit Pareek, Advocates. CORAM: HON'BLE MR. JUSTICE VIBHU BAKHRU HON'BLE MR. JUSTICE TEJAS KARIA VIBHU BAKHRU, J. (ORAL) 1. The petitioner has filed the present petition seeking various reliefs. However, the learned counsel appearing for the petitioner has confined the present petition to the first prayer, which is reproduced below: “(I) Issue a writ in the nature of mandamus/ certiorari or any other appropriate writ, order or direction for quashing: (a) the notice dated 08.04.2021 issued under section 148, as it existed prior to substitution vide Finance Act, 2021 w.e.f. 01.04.2021, and now deemed to be notice under section 148A(b) of the Income Tax Act, 1961 (‘the Act’); (b) the letter/ notice dated 20.05.2022 issued by Respondent No.1 communicating the so-called information/ material forming the basis of proceedings under section 148/148A of the Act; Signature Not Verified Digitally Signed By:GANGA SINGH RAWAT Signing Date:16.04.2025 19:41:21 W.P.(C) 297/2023 Page 1 of 9 (c) the order dated 22.07.2022 passed by Respondent No.1 [with the prior approval of Respondent No.2] under section 148A(d), and the consequent initiation of reassessment proceedings vide notice dated 22.07.2022 issued under section 148 of the Act; in the case of the Petitioner for assessment year 2014- 15, and all proceedings/ actions consequent thereto;” 2. The petitioner, essentially, impugns a notice dated 22.07.2022 [impugned notice] issued under Section 1