PICO CAPITAL PRIVATE LIMITED vs DEPUTY COMMISSIONER OF INCOME-TAX CIRCLE 8(2)(1)

2025:BHC-OS:217-DB Sayyed 7-WP(L).15940.2024.docx IN THE HIGH COURT OF JUDICATURE AT BOMBAY ORDINARY ORIGINAL CIVIL JURISDICTION WRIT PETITION (L) NO.15940 OF 2024 Pico Capital Private Limited ...Petitioner Versus Deputy Commissioner of Income-Tax Circle 8(2)(1) & Ors. ...Respondents _____________________________________________________ Mr. Dharan V. Gandhi for Petitioner. Mr. Dhanajay B. Deshmukh for Respondents. _____________________________________________________ CORAM : M. S. Sonak & Jitendra Jain, JJ. DATED: 7 January 2025 ORAL JUDGMENT:- (Per M. S. Sonak J) 1. Heard learned counsel for the parties. 2. Rule. The Rule is made returnable immediately at the request and with the consent of the learned counsel for the parties. 3. The challenge in this petition is to the assessment order dated 26 March 2024 and notice dated 31 March 2023 disposing of objections under Section 148A(d) of the Income Tax Act, 1961. 4. At the outset, we clarify that we are not considering the challenge to the notice dated 31 March 2023, but we propose to consider the challenge to the assessment order dated 26 March 2024 on the ground that it was made in breach of the principles of natural justice. 5. Th