BAKLIWAL HOLDINGS PRIVATE LIMITED vs UNION OF INDIA THROUGH THE SECRETARY MINISTRY OF FINANCE DEPARTMENT OF REVENUE & ORS.

Judgment text excerpt

$~15-19 * IN THE HIGH COURT OF DELHI AT NEW DELHI % Date of Decision : 28.11.2025 + W.P.(C) 16866/2025 & CM APPL. 69385/2025 + W.P.(C) 17316/2025 & CM APPL. 71285/2025 + W.P.(C) 17362/2025 & CM APPL. 71456/2025 + W.P.(C) 17363/2025 & CM APPL. 71460/2025 + W.P.(C) 17365/2025 & CM APPL. 71471/2025 BAKLIWAL HOLDINGS PRIVATE LIMITED .....Petitioner Through: Mr Subhash Agarwal, Mr Aneesh Mittal, Ms Komal Mittal and Mr Maasir Javed, Advocates. versus UNION OF INDIA THROUGH THE SECRETARY MINISTRY OF FINANCE DEPARTMENT OF REVENUE & ORS. .....Respondents Through: Ms Akanksha Gupta, SPC for UOI. Mr. Gaurav Gupta, SSC, Mr. Shivendra Singh, Mr. Yojit Pareek, JSCs, Mr Surya Jindal, Advocate for the Revenue. CORAM: HON'BLE MR. JUSTICE V. KAMESWAR RAO HON'BLE MR. JUSTICE VINOD KUMAR V. KAMESWAR RAO , J. (ORAL) 1. The learned counsel appearing for the petitioner states that these petitions have been filed with common and identical prayers, inter alia, challenging the notice dated 31.08.2024 (impugned notice) issued under Section 148 of the Income Tax Act, 1961 (the Act) in respect of the Assessment Years (AYs) 2011-12 to 2016-17 respectively. Prior to issuance of the impugned notices, the notices under Section 148A(b) of the Act and orders under Section 148A(d) of the Act were passed. Signature Not Verified Signed By:PRADEEP W.P. (C) 16866/2025 & connected Page 1 of 3 SHARMA Signing Date:02.12.2025 11:59:19 2. The common submission made by the learned counsel for the petitioner is that the notices under Section 148A(b) of the Act itself was barred by limitation, which would make the subsequent orders passed under Section 148A(d) and also the impugned notices under Section 148 of the Act are barred by limitation. 3. According to the learned counsel for the petitioner, the limitation per