RAM BALRAM BUILDHOME PVT LTD vs INCOME TAX OFFICER & ANR.

Judgment text excerpt

IN THE HIGH COURT OF DELHI AT NEW DELHI % Judgment delivered on: 30.01.2025 + W.P.(C) 16232/2024 & CM APPL. 68188/2024 RAM BALRAM BUILDHOME PVT. LTD. ..... Petitioner Versus INCOME TAX OFFICER AND ANR. ..... Respondents Advocates who appeared in this case: For the Petitioner : Mr Keshav Sehgal, Mr Shivam Gaur, Mr Kshitij Joshi and Mr Aryan Kumar, Advocates. For the Respondent : Mr. Aseem Chawla, Sr. Advocate with Ms. Pratishtha Choudhary, Mr Puneet Rai, Senior Standing Counsel with Mr Ashvini Kumar and Mr Rishabh Nangia, Advocates. CORAM HON’BLE THE ACTING CHIEF JUSTICE HON’BLE MR JUSTICE TUSHAR RAO GEDELA JUDGMENT VIBHU BAKHRU, J INTRODUCTION 1. The petitioner (hereafter the Assessee) has filed the present petition under Article 226 of the Constitution of India, inter alia, impugning (i) a notice dated 01.06.2021 issued under Section 148 of the Income Tax Act, 1961 (hereafter the Act); (ii) a notice dated 30.05.2022 Signature Not Verified Digitally Signed By:TARUN RANA W.P.(C) 16232/2024 Page 1 of 45 Signing Date:30.01.2025 15:47:48 issued in furtherance of the notice dated 01.06.2021; (iii) an order dated 30.07.2022 passed under Section 148A(d) of the Act; (iv) a notice dated 30.07.2022 issued under Section 148 of the Act; and (v) an assessment order dated 30.05.2023 framed under Section 147 of the Act read with Section 144 and 144B of the Act. These abovementioned impugned notices and orders were issued in respect of the assessment year (AY) 2013-14. 2. Mr Sehgal, the learned counsel appearing for the Assessee has confined the challenge to the notices and the orders impugned in this petition on a singular ground – that the order dated 30.07.2022 passed under Section 148A(d) of the Act (hereafter the impugned order) as well as the notice dated 30.07.2022 (hereafter th