IRIS HOSPITALITIES PRIVATE LIMITED vs. INCOME TAX OFFICER, WARD 12(1) DELHI & ORS.

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W.P.(C)/16840/2025HC DelhiDLHC01086832202502 February 2026Author: HON'BLE MR. JUSTICE DINESH MEHTA,HON'BLE MR. JUSTICE VINOD KUMAR2 pages
AI SummaryDisposed of

What did the High Court hold?

The Delhi High Court disposed of the writ petitions based on the assurances provided by the respondent's counsel. The court noted the submission that while reassessment proceedings might be initiated for two assessment years, the petitioner would only be assessed in one of those years concerning the deeming fiction under Section 56 of the Income Tax Act. Additionally, the court was assured that a single Assessing Officer would pass orders for both proceedings to prevent any harassment or duplication of income. Consequently, the court found no reason to continue with the writ petitions and disposed of them in terms of the statement made by the respondent's counsel.

What were the facts?

The petitioner, Iris Hospitalities Private Limited, filed two writ petitions before the Delhi High Court challenging notices for reassessment under Section 148 of the Income Tax Act, 1961. These notices were issued for assessment years 2019-20 and 2020-21. The primary contention of the petitioner was that reassessment proceedings for both years could not be initiated for the same underlying reason. The respondent, Income Tax Officer, Ward 12(1) Delhi, through its counsel, submitted that while reassessment proceedings might be initiated for two years, the petitioner would only be assessed in one of those years concerning the deeming fiction under Section 56 of the Act. Furthermore, it was assured that a single Assessing Officer would pass orders for both proceedings to prevent harassment and duplication of income.

What were the issues?

1. Whether reassessment proceedings under Section 148 of the Income Tax Act, 1961, can be initiated for two assessment years (2019-20 and 2020-21) on the same grounds, and if so, what is the implication for the assessee? Assessee's contention: The petitioner argued that initiating reassessment for two years on the same basis is impermissible and would lead to duplication of proceedings and potential harassment. Revenue's contention: The respondent submitted that reassessment proceedings could be undertaken for two years, but the assessment itself, particularly concerning the deeming fiction under Section 56, would be confined to one year. They also assured that a single Assessing Officer would handle both cases to avoid duplicity and harassment.

Which sections of the Income-tax Act were involved?

Section 148,Section 56

AI-generated summary — verify with the full judgment below

Heard together (2 matters)

W.P.(C) 16840/2025
W.P.(C) 16924/2025

Read from the judgment's own cause title. This page is filed under one of them.

Cause title — parties, addresses and appearances
$~4 & 5 * IN THE HIGH COURT OF DELHI AT NEW DELHI + W.P.(C) 16840/2025 & CM APPL. 69220/2025 + W.P.(C) 16924/2025 & CM APPL. 69576/2025 IRIS HOSPITALITIES PRIVATE LIMITED .....Petitioner Through: Mr. Mayank Patwani, Mr. Akash Ojha, Advs. versus INCOME TAX OFFICER, WARD 12(1) DELHI & ORS. .....Respondents Through: Mr. Abhishek Maratha, SSC, Mr. Apoorv Agarwal, JSC, Ms. Nupur Sharma, Adv. Ms. Babita Saini, SPC. CORAM: HON'BLE MR. JUSTICE DINESH MEHTA HON'BLE MR. JUSTICE VINOD KUMAR

O R D E R %

02.02.

2026

1.

By way of these writ petitions, the petitioner has challenged the notices for reassessment under Section 148 of the Income Tax Act, 1961 against the petitioner for assessment year 2019-20 so also for assessment year 2020-21. 2. The basic plank for which the petition has been preferred is, that the reassessment proceedings for 2 assessment years cannot be undertaken for the very same reason.

3.

Pursuant to Court’s query, learned counsel for the respondent submitted that maybe the reassessment proceedings had been undertaken for 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 04/02/2026 at 13:39:21

2 years, but the petitioner shall be assessed only in one of the years so far as deeming fiction given under Section 56 of the Income Tax Act is concerned.

4.

It was further assured that only one Assessing Officer shall pass orders for both the proceedings, so as to ward off any harassment or duplicacy of the income.

5.

In view of the assurance so given by Mr. Apoorv Agarwal, we are not inclined to continue with the present writ petitions.

6.

Writ petitions, therefore, stand disposed of in terms of the statement so given by Mr. Agarwal.

DINESH MEHTA, J.

VINOD KUMAR, J. FEBRUARY 2, 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 04/02/2026 at 13:39:21

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