CONNER INSTITUTE OF HEALTH CARE AND RESEARCH CENTER PVT. LTD vs DCIT, CIRCLE- 73(1), DELHI

IN THEHIGH COURTOF DELHIAT NEW DELHI Date of Decision: 30.04.2025 W.P.(C) 16978/2022 CONNER INSTITUTE OF HEALTH CARE AND RESEARCH CENTER PVT. LTD .....Petitioner Through: Mr Mukesh Gupta and Mr S.B. Gandhi, Advocates. versus DCIT, CIRCLE- 73(1), DELHI .....Respondent Through: Mr Ruchir Bhatia, senior standing counsel with Mr Anant Mann, Ms Aditi Sabharwal and Mr Abhishek Anand, 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 impugning a notice dated 19.03.2021 [impugned notice] issued under Section 201 of the Income Tax Act, 1961 [the Act] in respect of financial year [FY] 2015-16. 2. The subject matter of the said notice indicates that it is for the verification under Section 201(1)/201(1A) of the Act and for furnishing details/information. It is the petitioner’s contention that Section 201(1) of the Act does not contemplate any proceedings, which are akin to assessment 3. At the outset, it is relevant to refer to Section 201 of the Act, which reads as under: “201. Consequences of failure to deduct or pay. —(1) Where any person, including the principal officer of a company,