LATE SH. LAL CHAND VERMA THROUGH HIS LEGAL HEIR vs UNION OF INDIA & ANR.

Judgment text excerpt

* IN THE HIGH COURT OF DELHI AT NEW DELHI % Judgment reserved on : 13 December 2024 Judgment pronounced on: 08 January 2025 + W.P.(C) 8184/2023 & CM APPL. 31377/2023 (Stay) LATE SH. LAL CHAND VERMA THROUGH HIS LEGAL HEIR .....Appellant Through: Mr. Rohan Gupta & Mr. Vaibhav Grover, Advs. versus UNION OF INDIA & ANR. .....Respondents Through: Mr. Vipul Agrawal, SSC with Mr. Gibran Naushad & Ms. Sakashi Shairwal, JSCs for Respondent/Revenue. CORAM: HON'BLE MR. JUSTICE YASHWANT VARMA HON'BLE MR. JUSTICE DHARMESH SHARMA JUDGMENT DHARMESH SHARMA, J. 1. The petitioner, namely, Puneet Verma being the son and legal heir of the deceased assessee late Lal Chanda Verma (PAN No. ACNPV6482A), invokes the extra ordinary writ jurisdiction of this Court under Article 226 of the Constitution of India, 1950, for issuance of an appropriate writ or direction against the respondents, thereby seeking quashing of the impugned Notice bearing No. ITBA/AST/F/148A(SCN)/2022-23/1051639222(1) dated 30 March W.P.(C) 8184/2023 Page 1 of 9 Signature Not Verified Digitally Signed By:PRAMOD KUMAR VATS Signing Date:09.01.2025 11:01:25 2023 issued under Section 148A(b) of the Income Tax Act, 1961 [„the Act‟] and subsequent proceedings thereto. FACTUAL MATRIX: 2. Shorn of unnecessary details, the original assessee Lal Chand Verma passed away on 30 July 2021. It appears that the Income Tax Officer acting on the basis of a statement purportedly made by another assessee, namely, Sh. Sanjay Jain during assessment proceedings pertaining to the latter, proceeded to issue a notice under Section 148A(b)1 of the Act, in relation to the Assessment Year 2019-2020, dated 30 March 2023, calling upon the deceased assessee to furnish an explanation as to why certain financial transactions should not be considered as inco