R.C. JEWELLERS PVT.LTD. vs DEPUTY COMMISSIONER OF INCOME TAX, CENTRAL CIRCLE 32, DELHI

Judgment text excerpt

$~32 * IN THE HIGH COURT OF DELHI AT NEW DELHI % Date of Decision: 29.04.2024 + W.P.(C) 4622/2021 R.C. JEWELLERS PVT.LTD. .....Petitioner Through: Mr Salil Kapoor, Mr Sumit Lalchandani, Ms Ananya Kapoor and Mr Tarun Chanana, Advocates. Versus DEPUTY COMMISSIONER OF INCOME TAX, CENTRAL CIRCLE 32, DELHI .....Respondent Through: Mr Abhishek Maratha, senior standing counsel with Mr Apoorv Agarwal, Mr Parth Samwal, Ms Nipur Sharma, Mr Gaurav Singh, Mr Bhanukaran Singh Jodha, Mr Himanshu Guar and Ms Muskaan Goel, Advocates. CORAM: HON'BLE MR. JUSTICE VIBHU BAKHRU HON'BLE MR. JUSTICE TEJAS KARIA VIBHU BAKHRU, J. 1. The petitioner has filed the present petition, inter alia, impugning the separate notices dated 26.12.2019 [impugned notices] issued under Section 153C of the Income Tax Act, 1961 [the Act] in respect of Assessment Years [AYs] 2012-13, 2013-14, 2014-15, 2015-16, 2016-17, and 2017-18. The petitioner also impugns an order dated 17.03.2021 [impugned order] passed by the Assessing Officer [AO] disposing of the petitioner’s objections and prays that the respondent be restrained from proceeding further pursuant to the aforesaid impugned notices. W.P.(C) 4622/2021 Page 1 of 5 Signature Not Verified Digitally Signed By:TARUN RANA Signing Date:03.05.2025 16:11:13 2. The petitioner seeks to impugn the notices, inter alia, on the ground that no incriminating material was found pursuant to the search conducted under Section 132 of the Act or a requisition made under Section 132A of the Act in respect of any other person (other than the petitioner) which would have a bearing on the income of the petitioner. The petitioner also contends that the impugned notices have been issued beyond the period of limitation. 3. The relevant facts necessary to address the aforesaid challenge ar