SIAM STOCK HOLDINGS LIMITED vs ASSISTANT/ DEPUTY COMMISSIONER OF INCOME TAX CIRCLE INTERNATIONAL TAXATION 3(1)(2) & ORS.

Judgment text excerpt

$~48 * IN THE HIGH COURT OF DELHI AT NEW DELHI % Date of Decision : 19.09.2025 + W.P.(C) 14580/2025 CM APPL. 59830/2025 SIAM STOCK HOLDINGS LIMITED .....Petitioner Through: Mr. Rohit Jain and Mr. Samarth Chaudhari, Advs. versus ASSISTANT/ DEPUTY COMMISSIONER OF INCOME TAX CIRCLE INTERNATIONAL TAXATION 3(1)(2) & ORS. .....Respondents Through: Mr. Siddharth Sinha, SSC CORAM: HON'BLE MR. JUSTICE V. KAMESWAR RAO HON'BLE MR. JUSTICE VINOD KUMAR V. KAMESWAR RAO , J. (ORAL) CM APPL. 59831/2025 1. Exemption allowed, subject to all just exceptions. 2. The application is disposed of. W.P.(C) 14580/2025 and CM APPL. 59830/2025 3. This petition has been filed with the following prayers : “(I) Issue a writ in the nature of certiorari/ mandamus or any other appropriate writ, order or direction for quashing: (a) show-cause notice dated 17.03.2023 issued by Respondent No.1 under section 148A(b) of the Income Tax Act, 1961 (’the Act’); (b) order dated 17.04.2023 passed by Respondent No.1 under section 148A(d) of the Act with prior approval of Respondent No.2, W.P.(C) 14580/2025 Page 1 of 4 (c) reassessment notice dated 17.04.2023 issued by Respondent No.1 under section 148 of the Act; (d) ex-parte best judgment assessment order dated 13.05.2025 passed by Respondent No.1 under sections 147/144 of the Act, along with consequential notice of demand dated 13.05.2025 issued under section 156 of the Act; (e) penalty notices [dated 13.05.2025] issued by Respondent No.1 under sections 271AAA, 271AAC(1) & 272A(1)(d) of the Act; (f) email communication dated 09.07.2025 of outstanding income tax demand(s) issued by Respondent No.3, in the case of the Petitioner for assessment year 2019-20, and all proceedings/ actions consequent thereto; (II) stay effect and operation of the impugned assessment or