PFIZER LIMITED vs THE DEPUTYCOMMISSIONER OF INCOME TAX CIRCLE 10 (3) (2) MUMBAI AND 3 OTHERS

Judgment text excerpt

1 SAYYED 903.WP.2922.16(J).docx SAEED ALI Revati AHMED ALI Digitally signed by IN THE HIGH COURT OF JUDICATURE AT BOMBAY SAYYED SAEED ALI AHMED ALI ORDINARY ORIGINAL CIVIL JURISDICTION Date: 2025.03.20 15:25:27 +0530 WRIT PETITION NO.2922 OF 2016 Pfizer Limited (As successor of Wyeth Limited) The Capital, 1802/1901, Plot No.C-70, G Block, Bandra Kurla Complex, Bandra (East), Mumbai-400051 …Petitioner Versus 1. The Deputy Commissioner of Income-tax,Circle 10(3)(2), Mumbai, Room No.509, 5th floor, Aayakar Bhavan, M.K.Road, Mumbai-400020 2. The Deputy Commissioner of Income tax 14(2)(2), Mumbai, Room No.461, 4th floor, Aayakar Bhavan, Maharshi Karve Road, Mumbai-400020. 3. The Principal Commissioner of Income tax-10, Aayakar Bhavan, Maharshi Karve Road, Mumbai-400020. 4. Union of India Through the Secretary, Department of Revenue, Ministry of Finance, Government of India, North Block, New Delhi-110001. …Respondents ______________________________________________________ Mr. Madhur Agrawal i/by Mr. Atul K Jasani, for the Petitioner. Mr Suresh Kumar, for the Respondent/Revenue. ______________________________________________________ 2 903.WP.2922.16(J).docx CORAMM.S. Sonak & Jitendra Jain, JJ. RESERVED ON: 18 March 2025 PRONOUNCED ON: 20 March 2025 JUDGMENT (Per Jitendra Jain, J):- 1. This petition challenges notice under Section 148 of the Income-tax Act ,1961 (hereinafter referred to as 'the Act') dated 29 March 2016 for the Assessment Year (AY) 2009–10 seeking to reopen the assessment made on 18 April 2013 under Section 143 of the Act. This petition was admitted on 20 December 2016, and the impugned notice dated 29th March 2016 was stayed till final disposal of the petition. Brief Facts: 2. The original income return for AY 2009-10 was filed on 30 September 2009 and revised