Accost Media LLP vs Deputy Commissioner of Income tax Circle 27(1) And Ors

Judgment text excerpt

46.wp(l).35160.2025.doc IN THE HIGH COURT OF JUDICATURE AT BOMBAY ORDINARY ORIGINAL CIVIL JURISDICTION WRIT PETITION (L) NO.35160 OF 2025 Accost Media LLP .. Petitioner Versus UTKARSH KAKASAHEB Deputy Commissioner of Income Tax, BHALERAO Digitally signed by Circle 27(1), Mumbai & Ors. .. Respondents UTKARSH KAKASAHEB BHALERAO Date: 2025.12.04 15:21:17 +0530 Mr. P. J. Pardiwalla, Senior Counsel a/w Gunjan Kakkad i/b Mind and Confreres, Advocates for the Petitioner. Mr. Arjun Gupta, Advocate for the Respondents. CORAM : B. P. COLABAWALLA & AMIT S. JAMSANDEKAR, JJ. DATE : DECEMBER 01, 2025 ORAL JUDGMENT [PER B. P. COLABAWALLA, J.] 1. The above Writ Petition has been filed seeking to quash and set aside the order dated 13 th October 2025 passed under Section 254(2) of the Income Tax Act, 1961. 2. Mr. Pardiwalla, the learned senior counsel appearing on behalf of the Petitioner submitted that the impugned order rejecting the Rectification Application [filed under Section 254(2)] by the Petitioner, Page 1 of 10 DECEMBER 01, 2025 Utkarsh 46.wp(l).35160.2025.doc was mainly on the ground that the same was barred by the law of limitation. According to Mr. Pardiwalla, in the facts of the present case, the ITAT’s order of which rectification was sought, is dated 10 th December 2024. The said order was received by the Petitioner on 24 th March 2025. Accordingly, the Petitioner, on 16 th July 2025, filed the Miscellaneous Application seeking rectification of the order dated 10 th December 2024. Since the Miscellaneous Application was filed beyond the period of 6 months from the end of the month in which the ITAT’s order was passed (10th December 2024), the Petitioner received a notice from the Registry of the Tribunal that the Application is belated by 15 days. In reply to this notice