LALIT GULATI vs ASSISTANT COMMISSIONER OF INCOME TAX, CIRCLE 28(1), DELHI & ORS.

IN THE HIGH COURT OF DELHI AT NEW DELHI Date of Decision : 02.05.2025 W.P.(C) 6216/2023 & CM APPL. 18288/2025 LALIT GULATI .....Petitioner Through: Mr Ved Jain, Mr Nischay Kantoor, Ms Soniya Dodeja, and Mr Sarthak Abrol, Advocates. versus ASSISTANT COMMISSIONER OF INCOME TAX, CIRCLE 28(1), DELHI & ORS. .....Respondents Through: Mr Abhishek Maratha, SSC, Mr Apoorv Agarwal, Mr Parth Samwal, JSCs, Ms Nupur Sharma, Mr Gaurav Singh, Ms Muskaan Goel, Mr Bhanukaran Singh Jodha, Advocates for the Revenue 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 a notice dated 23.07.2022 issued under Section 148 of the Income Tax Act, 1961 [the Act] and further proceedings pursuant to the said notice in respect of Assessment Year [AY] 2015-16. 2. The petitioner filed its return of income for the AY 2015-16 on 3. The Assessing Officer [AO] issued a notice dated 05.04.2021 under Section 148 of the Act seeking to reopen the assessment for AY 2015-16. Although the said notice was issued after 31.03.2021, the procedure as prescribed under Section 148A of the Act was not followed, as the