BKR CAPITAL PVT. LTD vs INCOME TAX OFFICER, WARD 4.1., DELHI

Judgment text excerpt

$~80 & 81 * IN THE HIGH COURT OF DELHI AT NEW DELHI % Date of decision: 26th February,2026 + W.P.(C) 19738/2025 & CM APPL. 82448/2025 BKR CAPITAL PVT. LTD .....Petitioner Through: Mr. Mukul Katyal, Adv. versus INCOME TAX OFFICER, WARD 4.1., DELHI .....Respondent Through: Mr. Ruchir Bhatia, SSC with Mr. Anant Mann, JSC. + W.P.(C) 19769/2025 & CM APPL. 82587/2025 RAJMANI SECURITIES PVT LTD .....Petitioner Through: Mr. Mukul Katyal, Adv. versus INCOME TAX OFFICER, WARD 21.1., DELHI .....Respondent Through: Mr. Sunil Agarwal, SSC with Ms. Monica Benjamin, JSC, Mr. Gibran Naushad, JSC & Mr. Rohit Chakraborty, Adv. CORAM: HON'BLE MR. JUSTICE DINESH MEHTA HON'BLE MR. JUSTICE VINOD KUMAR JUDGMENT REPORTABLE DINESH MEHTA, J. (ORAL) 1. By way of the instant petitions preferred under Article 226 of the Signature Not Verified Digitally Signed By:NAVEEN KUMAR W.P.(C) 19738/2025 & W.P.(C) 19769/2025 Page 1 of 14 Signing Date:11.03.2026 15:43:06 Constitution of India, the petitioners allege that the notices under section 148 of the Income Tax Act, 1961 (hereinafter referred to as the ‘Act of 1961’) which have been issued for Assessment Year (AY) 2017-18 on 15.04.2024, and 06.04.2024 are without jurisdiction, having been issued after the prescribed period of limitation. 2. As both the writ petitions involve identical facts and question of law, they are being decided conjointly. However, the facts of BKR Capital Pvt. Ltd., being W.P.(C) 19738/2025, are being taken into consideration. 3. The petitioner filed its return of income for AY 2017-18 on 29.10.2017, declaring an income of Rs.13,63,270/-. The respondent- Assessing Officer (AO) issued a show-cause notice dated 21.03.2024 to the petitioner for the purpose of reassessment, invoking the provisions of section 148A(b) of the Act of 196