AKC RETAILERS PRIVATE LIMITED vs INCOME TAX OFFICER & ANR.

Judgment text excerpt

$~30 * IN THE HIGH COURT OF DELHI AT NEW DELHI % Date of Decision : 10.12.2025 + W.P.(C) 1606/2023 CM APPL. 6101/2023 AKC RETAILERS PRIVATE LIMITED .....Petitioner Through: Ms. Kavita Jha, Sr. Adv. with Mr. Himanshu Aggarwal, Adv. versus INCOME TAX OFFICER & ANR. .....Respondents Through: Mr. Debesh Panda, SSC, Ms. Zehra Khan, JSC, Mr. Vikramaditya Singh, JSC and Ms. Ravicha Sharma, Adv. CORAM: HON'BLE MR. JUSTICE V. KAMESWAR RAO HON’BLE MR. JUSTICE SAURABH BANERJEE V. KAMESWAR RAO , J. (ORAL) 1. This petition has been filed with the following prayers:- “(I) writ of certiorari or writ, order or direction in the nature of certiorari, or any other appropriate writ, order or direction under Article 226/227 of the Constitution of India, quashing notice dated 27.05.2022 issued under section 148A(b) of the Income Tax Act, 1961 („the Act‟); (II) writ in the nature of mandamus/ certiorari or any other appropriate writ, order or direction for quashing of the impugned order dated 22.07.2022 passed by Respondent No.1 under section 148A(d) of the Act, and the consequent initiation of reassessment proceedings for AY 2013-14, and all proceedings/ actions consequent thereto” Signature Not Verified Signed By:PRADEEP W.P.(C) 1606/2023 Page 1 of 4 SHARMA Signing Date:11.12.2025 19:18:52 2. The submission of learned counsel for the petitioner is that the notice under Section 148 of the Income Tax Act, 1961 dated 22.07.2022 which is relatable to the assessment year 2013-14 has been passed beyond the period of six years, which expired on 17.06.2022. 3. According to him, the issue in hand is covered by the judgment in the case of Kanwaljeet Kaur v. Commissioner of Income Tax, 2025 SCC OnLine Del 605. He has also placed before us a summary chart, which reads as under:- “A. Key Facts: S. PARTI