J.G S DEPARTMENTAL STORE vs INCOME TAX OFFICER WARD 60(1) & ORS.

Judgment text excerpt

* IN THE HIGH COURT OF DELHI AT NEW DELHI % Judgement delivered on: 15.04.2025 + W.P.(C) 13669/2024 & CM APPL. 57292/2024 J. G’S DEPARTMENTAL STORE ..... Petitioner versus INCOME TAX OFFICER WARD 60(1) & ORS. ..... Respondents Advocates who appeared in this case For the Petitioner : Mr. Ved Jain, Mr. Nischay Kantoor, Ms. Soniya Dodeja, Mr. Divyansh Dubey and Mr. Govind Gupta, Advocates. For the Respondents : Mr. Shlok Chandra, Standing Counsel with Ms. Naincy Jain, Advocate. CORAM: HON'BLE MR. JUSTICE VIBHU BAKHRU HON'BLE MR. JUSTICE TUSHAR RAO GEDELA JUDGMENT VIBHU BAKHRU, J. 1. The petitioner [the Assessee] has filed the present petition under Article 226 of the Constitution of India, inter alia, impugning (i) notices dated 01.02.2024 and 14.02.2024 issued under Section 148A(b) of the Income Tax Act, 1961 [the Act]; (ii) an order dated 19.03.2024 passed under Section 148A(d) of the Act [impugned order]; (iii) a notice dated 19.03.2024 issued under Section 148 of the Act [impugned notice]; and (iv) Signature Not Verified Digitally Signed By:RAM W.P.(C) No.13669/2024 Page 1 of 10 KUMAR Signing Date:15.04.2025 18:20:13 the impugned approval purportedly granted by respondent no.2 [CCIT] under Section 151 of the Act. The above-mentioned notices and order were issued in respect of the assessment year [AY] 2017-18. 2. The Assessee is essentially aggrieved by the reopening of its assessment in respect of AY 2017-18 pursuant to the impugned notice issued under Section 148 of the Act. Although the Assessee has raised several grounds for assailing the impugned notice, Mr Ved Jain, learned counsel appearing for the Assessee, confined the challenge in the present petition to the ground that the order passed under Section 148A(d) of the Act is beyond the scope of the notice issued