CAPITAL IMPEX PVT LTD vs ASSISTANT COMMISSIONER OF INCOME TAX CIRCLE 4(2), DELHI

IN THE HIGH COURT OF DELHI AT NEW DELHI Date of Decision : 02.05.2025 W.P.(C) 5808/2025, CM APPL. 26442/2025 & CM APPL. 26443/2025 CAPITAL IMPEX PVT LTD .....Petitioner Through: Dr. Kapil Goel & Mr. Sandeep Goel, Advocates. versus ASSISTANT COMMISSIONER OF INCOME TAX CIRCLE 4(2), DELHI .....Respondent Through: Mr. Debesh Panda, Senior Standing Counsel with Ms. Zehra Khan, Jr. SC, Mr. Vikramaditya Singh, Jr.SC & Mr. Kanishk Aggrawal, Advocate. CORAM: HON'BLE MR. JUSTICE VIBHU BAKHRU HON'BLE MR. JUSTICE TEJAS KARIA VIBHU BAKHRU, J. (ORAL) 1. The petitioner has filed the present petition, inter alia, impugning the notice dated 30.03.2024 [the impugned notice] issued under Section 148 of the Income Tax Act, 1961 [the Act] seeking to reopen the assessment in respect of the Assessment Year [AY] 2014-15. 2. The petitioner’s case is that the impugned notice has been issued beyond the period of the limitation. 3. In the present case, the petitioner had filed its return of income for the 15. Based on the said material, the Assessing Officer [AO] issued the impugned notice on 30.03.2024. 4. Although the provisions of Section 153C of the Act are inapplicable in respect of searches conducted af