SAPPHIRE FOODS INDIA LTD. vs ASSISTANT COMMISSIONER OF INCOME TAX ACIT (OSD) DELHI & ORS.

Judgment text excerpt

* IN THE HIGH COURT OF DELHI AT NEW DELHI % Judgment Reserved on: 12.11.2025 Judgment delivered on: 16.02.2026 Judgment uploaded on: As per Digital Signature~ + W.P.(C) 6159/2023, CM APPL. 24241/2023 SAPPHIRE FOODS INDIA LTD. .....Petitioner versus ASSISTANT COMMISSIONER OF INCOME TAX ACIT (OSD) DELHI & ORS. .....Respondents Advocates who appeared in this case For the Petitioner : Mr. T. M. Shivakumar, Ms. Sanjana, Ms. Laxmi Pundir, Ms. Simmi Bagga and Ms. Palak Kumari, Advs. For the Respondents : Mr. Abhishek Maratha, SSC, Mr. Apoorv Agarwal, JSC with Ms. Nupur Sharma, Mr. Gaurav Singh, Mr. Bhanukaran Singh Jodha, Ms. Muskaan Goel, Mr. Himanshu Gaur and Mr. Nischay Purohit, Advs. CORAM: HON'BLE MR. JUSTICE V. KAMESWAR RAO HON'BLE MR. JUSTICE VINOD KUMAR JUDGMENT V. KAMESWAR RAO, J. 1. This petition has been filed with the following prayers: “1. Issue a writ of Certiorari or writ of mandamus or appropriate writ, direction or order a. setting aside the impugned order u/s 148A(d) of the Act and the accompanying notice u/s 148 of the Act Signature Not Verified Signed By:PRADEEP SHARMA Signing Date:16.02.2026 WP(C) No.6159/2023 Page 1 of 38 18:16:53 both date 31.03.2023 by Respondent No. 1 in the Petitioner’s case for A. Y. 2016-17. b. Quashing the proceedings initiated vide the impugned notice dated 31.03.2023 u/s 148 of the Act.” 2. The petition relates to the Assessment Year (AY) 2016-17, for which an order under Section 148A(d) of the Income Tax Act,1961 (‘the Act’) and a notice under Section 148 of the Act, both dated 31.03.2023 were issued by the respondent no.1, on the information available with him whereby he has called for the filing of the return of income (ITR) by the petitioner herein, within thirty days. FACTUAL BACKGROUND 3. At the outset, we may provide a bri