SHWETA JAIN vs ASSISTANT COMMISSIONER OF INCOME TAX, CENTRAL CIRCLE 3, DELHI & ANR.

IN THE HIGH COURT OF DELHI AT NEW DELHI Date of Decision: 14.01.2025 W.P.(C) 310/2025 & CM APPL. 1486-87/2025 SHWETA JAIN .....Petitioner Through: Mr Deepanshu Jain and Mr Shaantanu Jain, Advocates. versus ASSISTANT COMMISSIONER OF INCOME TAX, CENTRAL CIRCLE 3, DELHI & ANR. .....Respondents Through: Mr Sunil Aggarwal, SSC, Mr Shivansh B Pandya, Mr Viplav Acharya, JSCs and Mr Utkarsh Tiwari, Advocate. Mr Sandeep Vishnu, SPC, Advocate for R2/UOI. CORAM: HON'BLE THE ACTING CHIEF JUSTICE HON'BLE MR. JUSTICE TUSHAR RAO GEDELA VIBHU BAKHRU, ACJ. (ORAL) 1. The petitioner has filed the present petition, inter alia, impugning a notice dated 30.08.2024 (hereafter the impugned notice) issued under Section 148 of the Income Tax Act, 1961 (hereafter the Act) in respect of the assessment year (AY) 2015-16. The petitioner also challenges the constitutional validity of Explanation 2 to Section 148 of the Act. 2. Mr Jain, the learned counsel appearing for the petitioner has confined the present petition to assailing the impugned notice on the ground that it is barred by limitation. He submits that the controversy involved in the present 3. Undisputedly, the initiation of the reassessment proceeding