MANJEET KAUR DUGGAL vs INCOME TAX OFFICER WARD 52 1 DELHI

Judgment text excerpt

$~17 * IN THE HIGH COURT OF DELHI AT NEW DELHI % Date of Decision : 29.05.2025 + W.P.(C) 3405/2023 & CM APPL. 13157/2023 MANJEET KAUR DUGGAL .....Petitioner Through: Mr Gaurav Jai, Mr Shubham Gupta, and Ms Shalini, Advocates. versus INCOME TAX OFFICER WARD 52 1 DELHI .....Respondent Through: Mr. Debesh Panda, SSC Ms. Zehra Khan, Mr. Vikramaditya Singh, JSCs Ms Anauntta Shankar and Ms Ravicha Sharma, Advocates. 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 order dated 15.07.2022 [impugned order] passed under Section 148A(d) of the Income Tax Act, 1961 [the Act] and consequential notice dated 15.07.2022 [impugned notice] issued under Section 148 of the Act in respect of the Assessment Year [AY] 2013-14. The petitioner also prays that the Assessing Officer [AO] be restrained from taking any steps pursuant to the impugned notice. 2. The present petition was listed on 20.03.2023 and this Court passed the interim order that the proceedings pursuant to the impugned notice may continue, however, any adverse order if passed, shall the same would not be Signature Not Verified Digitally Signed W.P. (C) 3405/2023 Page 1 of 10 By:TARUN RANA Signing Date:02.06.2025 11:30:48 given effect to till further directions of the Court. There is no cavil that assessment order, which was passed subsequently would be subject to the outcome of the petitioner’s challenge in the present petition. 3. The petitioner has assailed the impugned order on several grounds including that the impugned notice was barred by limitation. This challenge is founded on two grounds. First, that the impugned order was issued beyond the prescribed period of limitation. The said order holding th