SANJAY SINGHAL vs. DEPUTY COMMISSIONER OF INCOME TAX

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W.P.(C)/1415/2025HC DelhiDLHC01004698202517 March 2025Author: HON'BLE MR. JUSTICE VIBHU BAKHRU,HON'BLE MR. JUSTICE TEJAS KARIA2 pages
AI SummaryDismissed

What did the High Court hold?

The Delhi High Court held that the petitioner's grievance did not survive. This conclusion was based on the submission made by the Revenue that the reassessment proceedings for the assessment years 2021-2022 and 2022-2023 had been completed. The Revenue further clarified that no additions were made during these completed proceedings. As the primary reason for filing the writ petitions was the challenge to the reassessment notices and the potential for additions, the completion of these proceedings without any adverse findings rendered the petitions infructuous. The Court, therefore, disposed of the writ petitions and all pending applications.

What were the facts?

The petitioner, Sanjay Singhal, filed two writ petitions before the Delhi High Court under Section 148 of the Income Tax Act, 1961. These petitions challenged notices for reassessment concerning assessment years 2021-2022 and 2022-2023. The Revenue informed the Court that reassessment proceedings for both assessment years have been completed. Crucially, the Revenue stated that no additions were made during these completed reassessment proceedings. Consequently, the petitioner's grievance, which was the basis for filing the writ petitions, was no longer extant.

What were the issues?

1. Whether the petitioner's grievance survives in light of the completed reassessment proceedings with no additions, as per Section 148 of the Income Tax Act, 1961. Assessee's Contention: The petitioner filed the writ petitions challenging the notices issued under Section 148. The underlying grievance was the initiation of reassessment proceedings. Revenue's Contention: The Revenue stated that reassessment proceedings for the assessment years 2021-2022 and 2022-2023 have been completed. Furthermore, the Revenue confirmed that no additions were made during these completed proceedings. This submission effectively addresses and resolves the petitioner's initial grievance.

Which sections of the Income-tax Act were involved?

Section 148

AI-generated summary — verify with the full judgment below

Heard together (2 matters)

W.P.(C) 1415/2025
W.P.(C) 1422/2025

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

Cause title — parties, addresses and appearances
$~46 & 48 * IN THE HIGH COURT OF DELHI AT NEW DELHI + W.P.(C) 1415/2025 & CM APPL. 6920/2025-Stay SANJAY SINGHAL .....Petitioner Through: Ms Shreya Jain and Mr. Gaurav Tanwar, Advs. versus DEPUTY COMMISSIONER OF INCOME TAX .....Respondent Through: Mr Debesh Panda, SSC with Mr Vikramaditya Singh and Ms Zehra Khan, Advocates. AND + W.P.(C) 1422/2025 & CM APPL. 6932/2025 SANJAY SINGHAL .....Petitioner Through: Ms Shreya Jain and Mr. Gaurav Tanwar, Advs. versus DEPUTY COMMISSIONER OF INCOME TAX .....Respondent Through: Mr Debesh Panda, SSC with Mr Vikramaditya Singh and Ms Zehra Khan, Advocates. CORAM: HON'BLE MR. JUSTICE VIBHU BAKHRU HON'BLE MR. JUSTICE TEJAS KARIA

O R D E R % 17.03.2025

1.

The petitioner has filed the present petitions under Section 148 of the Income Tax Act, 1961. 2. The learned counsel appearing for the Revenue informs this Court that pursuant to the said notices re-assessment in respect of the assessment years 2021-2022 and 2022-2023 have been completed and there have been no additions.

3.

In view of the above, it is clear that the petitioner’s grievance does not 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 01/07/2025 at 20:12:39

survive.

4.

The petitions are, accordingly, disposed of. All pending applications are also disposed of. VIBHU BAKHRU, J TEJAS KARIA, J MARCH 17, 2025 RK Click here to check corrigendum, if any 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 01/07/2025 at 20:12:39

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