ST ENGINEERING AEROSPACE ENGINES PTE LTD vs THE ASSISTANT COMMISSIONER OF INCOME TAX & ANR.

Judgment text excerpt

$~78 * IN THE HIGH COURT OF DELHI AT NEW DELHI + W.P.(C) 3197/2025 & CM APPL. 14928/2025 ST ENGINEERING AEROSPACE ENGINES PTE LTD .....Petitioner Through: Mr. Ajay Vohra, Sr.Adv. with Mr.Rohit Garg, Adv. versus THE ASSISTANT COMMISSIONER OF INCOME TAX & ANR. .....Respondents Through: Mr.Sunil Agarwal, SSC with Mr.Shivansh B Pandya, JSC, Mr.Viplav Acharya, JSC, Ms.Priya Sarkar, JSC, Mr.Utkarsh Tiwari, Adv. % Date of Decision: 12th March, 2025 CORAM: HON'BLE THE CHIEF JUSTICE HON'BLE MR. JUSTICE TUSHAR RAO GEDELA JUDGEMENT TUSHAR RAO GEDELA, J : (ORAL) 1. Present petition has been filed, inter alia, seeking the following prayers:- “a) Writ of Certiorari or Mandamus or an appropriate writ, order or direction setting aside Impugned Notice dated 03.05.2023 issued by the Respondent No.1 under Section 148 of the Act for the AY 2019-20 and the Impugned Order dated 03.05.2023 passed by the Respondent under Section 148A(d) of the Act; b) A Writ, Order or Direction in the nature of Mandamus or an order prohibiting / desist the Respondent No.1 from taking any further steps pursuant to the Impugned Notice and Impugned Order issued / passed by the Respondent No.1 for AY 2019-20; c) A Writ, Order or Direction in the nature of Mandamus or an order prohibiting the Respondent No.1 from framing assessment for AY 2019-20 against the Petitioner under Section 147 of the Act; Signature Not Verified Digitally Signed W.P.(C) 3197/2025 Page 1 of 7 By:VINOD KUMAR Signing Date:19.03.2025 15:36:37 d) Ad-interim stay in respect of the above prayers at (a) to (c); e) Pass any other relief which this Hon’ble Court may deem fit and proper in favour of the appellant in the facts and circumstances of the case.” 2. The notice under section 148A(b) of the Income Tax Act, 1961 (hereinafter referred as “the