ZOOM INSURANCE BROKERS PVT LTD vs. ASSISTANT COMMISSIONER OF INCOME TAX CIRCLE 25 1 & ANR.

W.P.(C)-13064/2026HC Delhi01 October 20269 pages
AI SummaryDismissed

What did the High Court hold?

The High Court dismissed the writ petition. The Court noted that the facts in the present case for AY 2020-21 were identical to the facts in the petitioner's own case for AY 2019-20, where a Coordinate Bench had previously refused to interfere and dismissed the writ petition. Guided by judicial discipline, the Court held that it could not take a view different from the one taken by the Coordinate Bench in the petitioner's prior case. Therefore, the writ petition was dismissed. The Court did not explicitly decide on the merits of the allegations concerning escaped income but relied on the precedent set by the dismissal of the earlier writ petition.

What were the facts?

The petitioner, Zoom Insurance Brokers Pvt Ltd, filed a writ petition challenging an order dated 30.06.2026 passed under Section 148A(3) and a notice dated 30.06.2026 issued under Section 148 of the Income Tax Act, 1961, for Assessment Year 2020-21. The petitioner argued that the current notice was almost identical to a previous notice dated 23.06.2025 for Assessment Year 2019-20, which was dismissed by the same court. The revenue contended that the petitioner's earlier writ petition for AY 2019-20 was dismissed, and therefore, the current petition should also be dismissed. The petitioner argued that the previous dismissal did not properly consider the case of T S G International Marketing Private Limited v. Income Tax Officer. The revenue countered that the T S G International case was an interim order, while the petitioner's own case judgment was final.

What were the issues?

1. Whether the present writ petition, challenging a notice under Section 148A(3) and Section 148 of the Income Tax Act, 1961, for AY 2020-21, should be dismissed on the grounds that a similar writ petition for AY 2019-20, involving identical facts and allegations, was previously dismissed by this Court. Assessee's Contention: The petitioner argued that the previous dismissal of their writ petition for AY 2019-20 did not adequately consider the judgment in T S G International Marketing Private Limited v. Income Tax Officer, W.P.(C) 9715/2025, and therefore, the current petition warrants consideration. Revenue's Contention: The revenue submitted that the petitioner had challenged an identical notice for AY 2019-20 via a writ petition, which this Court refused to entertain and dismissed. Therefore, the instant writ petition should also be dismissed. The revenue further distinguished the T S G International Marketing case by stating it was an interim order, whereas the judgment in the petitioner's own case was a final order.

Which sections of the Income-tax Act were involved?

Section 148A,Section 148,Section 147,Section 132,Section 149(1)(b)

AI-generated summary — verify with the full judgment below

Cause title — parties, addresses and appearances
W.P.(C) 13064/2026 Page 1 of 9 $~9 * IN THE HIGH COURT OF DELHI AT NEW DELHI Date of decision: 1st October, 2026 # CNR No. DLHC010423342026 + W.P.(C) 13064/2026 & CM APPLs. 60787/2026, 60788/2026 ZOOM INSURANCE BROKERS PVT LTD .....Petitioner Through: Mr. Mukesh Gupta, Advocate. versus ASSISTANT COMMISSIONER OF INCOME TAX CIRCLE 25 1 & ANR. .....Respondents Through: Mr. Ruchir Bhatia, SSC with Mr. Anant Mann, JSC & Mr. Pratyuksh Gupta, JSC. CORAM: HON'BLE MR. JUSTICE DINESH MEHTA HON'BLE DR. JUSTICE ADITI CHOUDHARY

J U D G M E N T DINESH MEHTA, J. (ORAL)

1.

By way of the present writ petition, the petitioner has challenged the order dated 30.06.2026 passed under Section 148A(3) of the Income Tax Act, 1961 (hereinafter referred to as „the Act of 1961‟) so also notice of the even date issued under Section 148 of the Act of 1961 for Assessment Year 2020-21 on various counts.

2.

Mr. Anant Mann, learned Junior Sta

The order continues below.

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