CNB FINWIZ LTD vs DCIT , CIRCLE 6(1)

IN THE HIGH COURT OF DELHI AT NEW DELHI % Judgment delivered on: 20.05.2025 W.P.(C) 14082/2018 CNB FINWIZ LTD .....Petitioner Through: Mr. S. Krishnan & Mr. Harshit, Advs. Versus DCIT, CIRCLE 6(1) .....Respondent Through: Mr. Gaurav Gupta, Mr. Shivendra Singh and Mr. Yojit Pareek, Advs. CORAM HON’BLE MR JUSTICE VIBHU BAKHRU HON'BLE MR. JUSTICE TEJAS KARIA JUDGMENT VIBHU BAKHRU, J 1. The petitioner has filed the present petition under Article 226 of the Constitution of India, inter alia, impugning a notice dated 31.03.2018 [impugned notice] issued by the respondent [Assessing Officer – the AO] under Section 148 of the Income Tax Act, 1961 [the Act] in respect of Assessment Year [AY] 2011-12. The petitioner also impugns an order dated 10.12.2018 [impugned order] passed by the AO rejecting the petitioner’s objections to the reasons recorded in writing for reopening of the assessment and issuance of the impugned notice. 2. The petitioner, essentially, challenges the jurisdiction of the AO to commence the reassessment proceedings in respect of AY 2011-12, inter alia, on the ground that the AO did not have any reason to believe 3. The petitioner is a company incorporated under the Compan