PR COMMISSIONER OF INCOME TAX CENTRAL DELHI 18 vs. CHOTTI LEASING FINANCE PVT LTD

$~79, 80 & 102 * IN THE HIGH COURT OF DELHI AT NEW DELHI + ITA 151/2025 PR COMMISSIONER OF INCOME TAX CENTRAL DELHI 18

.....Appellant Through: Mr Indruj Singh Rai, SSC with Mr Sanjeev Menon, Mr Rahul Singh, Mr Gaurav Kumar and Ms Varsha Sharma, Advocates. versus CHOTTI LEASING FINANCE PVT LTD .....Respondent Through: Mr Somil Agarwal and Mr Dushyant Agrawal, Advocates. AND + ITA 152/2025 PR. COMMISSIONER OF INCOME TAX CENTRAL CIRCLE 18 .....Appellant Through: Mr Indruj Singh Rai, SSC with Mr Sanjeev Menon, Mr Rahul Singh, Mr Gaurav Kumar and Ms Varsha Sharma, Advocates. versus CHOTTI LEASING FINANCE PVT LTD .....Respondent Through: Mr Somil Agarwal and Mr Dushyant Agrawal, Advocates. AND + ITA 153/2025 PRINCIPAL COMMISSIONER OF INCOME TAX, CENTRAL CIRCLE 18 .....Appellant Through: Mr Indruj Singh Rai, SSC with Mr Sanjeev Menon, Mr Rahul Singh, Mr Gaurav Kumar and Ms Varsha Sharma, Advocates. versus CHOTTI LEASING FINANCE PVT LTD .....Respondent Through: Mr Somil Agarwal and Mr Dushyant Agrawal, Advocates. CORAM: 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 27/03/2026 at 14:24:37

HON'BLE MR. JUSTICE VIBHU BAKHRU HON'BLE MR. JUSTICE TEJAS KARIA O R D E R %

15.05.2025 CM No.29465/2025 in ITA 151/2025 CM No.29466/2025 in ITA 152/2025 CM No.29645/2025 in ITA 153/2025 1. For the reasons stated in the applications, the delay in re-filing the appeals is condoned. 2. The applications are disposed of. ITA 151/2025 ITA 152/2025 ITA 153/2025 3. The learned counsel appearing for the Revenue submits that the batch of matters [ITA No.378/2022 captioned Pr. Commissioner of Income Tax (Central)-2 v. M/s Shushre Securities Pvt. Ltd.] involving the similar issue is pending consideration before this Court and is now listed on 28.10.2025. 4. We, accordingly, admit these appeals on the following question of law, which is framed in the said appeals as well: “A. Whether in law, the Tribunal was right in holding that reassessment proceedings under Section 147 of the Act cannot be initiated when proceedings under Section 143(3) of the Act have been declared annulled?” 5. Accordingly, list on 28.10.2025. VIBHU BAKHRU, J TEJAS KARIA, J MAY 15, 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 27/03/2026 at 14:24:37