RAJESH CHOPRA vs INCOME TAX OFFICER, WARD 62(1) DELHI

Judgment text excerpt

IN THE HIGH COURT OF DELHI AT NEW DELHI % Judgment delivered on: 28.05.2025 + W.P.(C) 12561/2022 RAJESH CHOPRA .... Petitioner Versus INCOME TAX OFFICER, WARD 62(1) DELHI.... Respondent Advocates who appeared in this case: For the Petitioner : Mr. Sumit Lalchandani, Mr. Shivam Yadav, Mr. Utkarsh Kumar Gupta and Ms. Ananya Kapoor, Advocates. For the Respondent: Mr. Debesh Panda, Senior Standing Counsel with Ms. Zehra Khan, Mr. Vikramaditya Singh and Ms. Delphina, Advocates. 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 impugning a notice dated 30.05.2022 issued under Section 148A(b) of the Income Tax Act, 1961 [the Act]; an order dated 22.07.2022 passed under Section 148A(d) of the Act [impugned order]; and a notice dated 22.07.2022 [impugned notice] issued under Signature Not Verified Digitally Signed By:TARUN RANA W.P,(C) 12561/2022 Page 1 of 16 Signing Date:29.05.2025 15:43:13 Section 148 of the Act pursuant to the impugned order in respect of the assessment year [AY] 2013-14. 2. The petitioner contends that the impugned notice has been issued beyond the period of limitation as prescribed under Section 149(1) of the Act and therefore, is liable to be set aside. FACTUAL CONTEXT 3. The petitioner is an individual and is a resident of New Delhi. The petitioner filed its return of income on 08.08.2013 for AY 2013-14 under Section 139(1) of the Act, declaring a total income of ₹20,59,151/-. 4. The petitioner received a notice dated 31.03.2021 under Section 148 of the Act. The petitioner complied with the said notice and furnished its return of income on 07.04.2021, declaring the income as was declared in the original return. There