RAKESH SURI vs ASSISTANT COMMISSIONER OF INCOME TAX & ORS.

IN THE HIGH COURT OF DELHI AT NEW DELHI Date of decision: 13.01.2026 W.P.(C) 4901/2025 RAKESH SURI .....Petitioner Through: Mr. S. Krishnan, Adv. versus ASSISTANT COMMISSIONER OF INCOME TAX & ORS. .....Respondents Through: Mr. Puneet Rai, SSC with Mr. Sahvini Kr., Mr. Rishabh Nangia & Mr. Gibran, JSC. CORAM: HON'BLE MR. JUSTICE DINESH MEHTA HON'BLE MR. JUSTICE VINOD KUMAR JUDGMENT DINESH MEHTA, J. (ORAL) CM APPL. 1991/2026 [For Stay] 1. By way of the present application, the petitioner has stated that the Assessing Officer(AO) is harassing him unnecessarily and had issued a notice dated 21.11.2025 under Section 142(1) of the Income Tax Act, 1961 (hereinafter referred to as “the Act of 1961”), asking him to furnish return qua PAN no. AOAPS6867H, whereas the petitioner has been using and filing his returns under PAN no. ALYPS4529D. It is the petitioner’s assertion that he had already filed a reply dated 25.04.2024 and requested the Assessing Officer to merge both the aforementioned PAN numbers. 2. It is also stated by the learned counsel for the petitioner that the respondents-Department may be allowed to make addition, if any found with respect to PAN no. AOAPS6867H, in the hands of