MARUTI SUZUKI INDIA LTD. vs DEPUTY COMMISSIONER OF INCOME TAX

* IN THE HIGH COURT OF DELHI AT NEW DELHI % Judgment reserved on: 18 October 2024 Judgment pronounced on 21 February, 2025 W.P.(C) 9786/2016 MARUTI SUZUKI INDIA LTD. .....Petitioner Through: Mr. Ajay Vohra, Sr. Adv. with Mr. Vaibhav Kulkarni and Mr. Udit Naresh, Advs. versus DEPUTY COMMISSIONER OF INCOME TAX .....Respondent Through: Mr. Shlok Chandra, SSC with Ms. Naincy Jain, Ms. Madhavi Shukla, JSCs and Mr. Sushant Pandey, Advs. CORAM: HON'BLE MR. JUSTICE YASHWANT VARMA HON'BLE MR. JUSTICE RAVINDER DUDEJA JUDGMENT YASHWANT VARMA, J. 1. The writ petitioner impugns the reassessment action initiated by the respondent under Sections 147/148 of the Income Tax Act, 19611 pertaining to Assessment Year2 2009-10. From the disclosures which are made in the writ petition, we find that although the petitioner is stated to have made appropriate disclosures along with the Return of Income3 including the filing of an Audit Report, Form No. 3CEB and a Tax Audit Report, the original RoI was subsequently revised declaring income of INR 12,62,60,79,909/-. The RoI was duly examined under 1 Act 2 AY 3 RoI 2. Undisputedly, 31 March 2016 constituted the last date by which a reassessment action for AY 2