DOLF LEASING LTD vs ACIT CIRCLE 7 1 DELHI AND ORS.

IN THE HIGH COURT OF DELHI AT NEW DELHI Date of Decision : 01.12.2025 W.P.(C) 18241/2025, CM APPL. 75414/2025 DOLF LEASING LTD .....Petitioner Through: Mr. R. Somnathanam, Mr. Rishabh and Mr. Deepak, Advs. versus ACIT CIRCLE 7 1 DELHI AND ORS. .....Respondents Through: Mr. Indruj Rai, SSC, Ms. Sanjeev Menon, JSC and Mr. Rahul Singh, JSC. CORAM: HON'BLE MR. JUSTICE V. KAMESWAR RAO HON’BLE MS. JUSTICE MINI PUSHKARNA V. KAMESWAR RAO , J. (ORAL) 1. This petition has been filed by the petitioner with the following prayers:- “A) To issue writ of certiorari or other appropriate writ, order or direction to quash the illegal notice u/s. 148 dt. 30.7.2022 and illegal order u/s. 148A(d) dt. 30.7.2022 (Annexures No. 5 & 6) and declare the same as barred by limitation, without jurisdiction and unauthorized by law. B) To issue writ of certiorari or other appropriate writ to quash the illegal order of reassessment dt. 27.05.2023 u/s 147 read with 144B by NFAC and declare the same as void ab initio and non-est in law and 2. The submission of learned counsel for the petitioner is that, though the petitioner, pursuant to the assessment order has approached the Commissioner of Income Tax (Appeals) [“