KAIROSOFT AI SOLUTIONS LIMITED FORMERLY PANKAJ PIYUSH TRADE AND INVESTMENT LIMITED vs. ASSISTANT COMMISSIONER OF INCOME TAX CENTRAL CIRCLE 31 DELHI & ANR.

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W.P.(C)/15635/2025HC DelhiDLHC01077865202529 September 2026Bench: HON'BLE DR. JUSTICE ADITI CHOUDHARY,HON'BLE MR. JUSTICE DINESH MEHTA2 pages
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What did the High Court hold?

The Delhi High Court allowed the writ petition. The Court accepted the petitioner's submission that the reassessment proceedings for assessment year 2015-16 were time-barred, as per the Supreme Court's order dated 04.05.2026 and the ratio laid down in paragraph 19(f) of the judgment in Union of India & Ors. v. Rajeev Bansal (2024 SCC OnLine SC 2693). Since the revenue did not contest this position, the Court found no reason to uphold the impugned notice and order. The Court quashed the notice dated 31.08.2024 issued under Section 148 of the Income Tax Act, 1961, and the order of even date passed under Section 148A(d) of the Act for the assessment year 2015-16. No issue was left undecided.

What were the facts?

The petitioner, Kairosoft AI Solutions Limited (formerly Pankaj Piyush Trade and Investment Limited), filed a writ petition before the Delhi High Court challenging a notice dated 31.08.2024 issued under Section 148 of the Income Tax Act, 1961, and an order of even date passed under Section 148A(d) of the Act. These actions pertained to the assessment year 2015-16. The petitioner argued that in light of a Supreme Court order dated 04.05.2026 and the Supreme Court's judgment in Union of India & Ors. v. Rajeev Bansal (2024 SCC OnLine SC 2693), specifically paragraph 19(f), the reassessment proceedings are time-barred. The respondent revenue, represented by the Assistant Commissioner of Income Tax, Central Circle 31 Delhi, did not dispute the petitioner's submissions.

What were the issues?

1. Whether the reassessment proceedings for assessment year 2015-16, initiated by a notice dated 31.08.2024 under Section 148 of the Income Tax Act, 1961, are liable to be declared time-barred in view of the Supreme Court's order dated 04.05.2026 and the judgment in Union of India & Ors. v. Rajeev Bansal (2024 SCC OnLine SC 2693)? (Question of law) Assessee's Contention: The petitioner argued that the reassessment proceedings are time-barred, relying on paragraph 19(f) of the Supreme Court's judgment in Union of India & Ors. v. Rajeev Bansal and a remand order passed by the Supreme Court on 04.05.2026. Revenue's Contention: The respondent revenue, through its counsel, stated it was not in a position to dispute the petitioner's submissions regarding the facts and the law.

Which sections of the Income-tax Act were involved?

Section 148,Section 148A

AI-generated summary — verify with the full judgment below

$~32 * IN THE HIGH COURT OF DELHI AT NEW DELHI # CNR No. DLHC010778652025 + W.P.(C) 15635/2025 & CM APPL. 63958/2025 KAIROSOFT AI SOLUTIONS LIMITED FORMERLY PANKAJ PIYUSH TRADE AND INVESTMENT LIMITED .....Petitioner Through: Mr. Anmol Jagga, Ms. Shagun Runil & Mr. Karan Chopra, Advocates. versus ASSISTANT COMMISSIONER OF INCOME TAX CENTRAL CIRCLE 31 DELHI & ANR.

.....Respondents Through: Mr. Shlok Chandra, SSC with Ms. Naincy Jain, JSC, Ms. Madhavi Shukla, JSC & Mr. Udit Dad, Adv. CORAM: HON'BLE MR. JUSTICE DINESH MEHTA HON'BLE DR. JUSTICE ADITI CHOUDHARY O R D E R %

29.09.2026 1. Mr. Anmol Jagga, learned counsel for the petitioner, invited Court’s attention towards the remand order passed by Hon’ble the Supreme Court on 04.05.2026 more particularly, paragraph no.5 thereof and submitted that the assessment year in question is 2015-16 and in view of paragraph no.19(f) of the judgment of Hon’ble the Supreme Court in the case of Union of India & Ors. v. Rajeev Bansal reported in 2024 SCC OnLine SC 2693, the reassessment proceedings under Section 148 of the Income Tax Act, 1961 (hereinafter referred to as ‘the Act of 1961’) are liable to be declared time-barred. This is a digitally signed order. The authenticity of the order can be re-verified from Delhi High Court Order Portal by scanning the QR code shown above. The Order is downloaded from the DHC Server on 01/10/2026 at 12:09:15

2.

Ms. Naincy Jain, learned Junior Standing Counsel, is not in a position to dispute the aforesaid position of the facts and law. 3. In view of the aforesaid, the writ petition is allowed. The impugned notice dated 31.08.2024 (annexure P-3) issued under Section 148 of the Act of 1961 and impugned order (annexure P-2) of even date passed under Section 148A(d) of the Act of 1961 for assessment year 2015-16 are hereby quashed. DINESH MEHTA, J. ADITI CHOUDHARY, J. SEPTEMBER 29, 2026/nk This is a digitally signed order. The authenticity of the order can be re-verified from Delhi High Court Order Portal by scanning the QR code shown above. The Order is downloaded from the DHC Server on 01/10/2026 at 12:09:15

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