EXPLORE SYNERGY SYNOCARE PRIVATE LIMITED vs. ASSISTANT COMMISSIONER OF INCOME TAX & ANR.

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W.P.(C)/19557/2025HC DelhiDLHC01106301202523 December 2025Bench: HON'BLE MR. JUSTICE V. KAMESWAR RAO,HON'BLE MR. JUSTICE VINOD KUMAR2 pages
AI SummaryDismissed

What did the High Court hold?

The Delhi High Court dismissed the writ petition. The Court observed that the challenge was confined only to the notice under Section 148A(b), the order under Section 148A(d), and the notice under Section 148, which were issued in April 2024. The Court noted that subsequent communications, including notices under Section 143(2) and Section 142(1), had also been issued. The Court found the challenge to be untenable, particularly because the impugned notices/order were issued approximately 1.5 years prior to the filing of the petition, making it 'quite late in the day' to challenge them. The High Court did not decide on the merits of the reassessment proceedings themselves but rather on the maintainability of the writ petition in light of the delay and the procedural developments.

What were the facts?

The petitioner, Explore Synergy Synocare Private Limited, filed a writ petition before the Delhi High Court challenging a notice under Section 148A(b) dated March 23, 2024, an order under Section 148A(d) dated April 22, 2024, and a notice under Section 148 dated April 22, 2024, all pertaining to Assessment Year 2020-21. The respondents are the Assistant Commissioner of Income Tax and another authority. The petition also noted subsequent notices issued, including under Section 143(2) and Section 142(1), along with reminder letters. The challenge was specifically confined to the three initial notices/order.

What were the issues?

1. Whether the writ petition challenging the notice under Section 148A(b), the order under Section 148A(d), and the notice under Section 148 for AY 2020-21 is maintainable, given that subsequent notices have also been issued and the challenge is confined only to these initial communications? The Assessee argued that the writ petition should be allowed, seeking to quash the impugned notice under Section 148A(b), the order under Section 148A(d), and the notice under Section 148, along with all consequential proceedings. The Revenue, through its counsel, did not explicitly record arguments in the judgment. However, the Court's observation implies a contention that the challenge was untenable due to the delay and the issuance of subsequent notices.

Which sections of the Income-tax Act were involved?

Section 148A(b),Section 148A(d),Section 148,Section 143(2),Section 142(1)

AI-generated summary — verify with the full judgment below

$~22 * IN THE HIGH COURT OF DELHI AT NEW DELHI + W.P.(C) 19557/2025 CM APPL. 81717/2025 CM APPL. 81718/2025 EXPLORE SYNERGY SYNOCARE PRIVATE LIMITED .....Petitioner Through: Mr. Stit Jain, Adv. versus ASSISTANT COMMISSIONER OF INCOME TAX & ANR. .....Respondents Through: Mr. Anurag Ojha, SSC, Ms. Hemlata Rawat, Mr. V.K. Saksena and Ms. Monica Benjamin, JSCs with Mr. Saurabh and Mr. Abhay Singh, Advs. CORAM: HON'BLE MR. JUSTICE V. KAMESWAR RAO HON'BLE MR. JUSTICE VINOD KUMAR O R D E R %

23.12.2025 1. This petition has been filed with the following prayer:- “a) Allow the present Writ Petition and issue any writ, order or direction in the nature of certiorari and/or mandamus and/or any other appropriate writ, order or direction in the nature thereof, quashing/ setting aside the impugned notice u/s 148A(b) dated 23.03.2024 bearing no. ITBA/AST/F/148A(SCN)/2023-24/1063270380(1); as well as the impugned order u/s 148A(d) dated 22.04.2024 bearing no. ITBA/ AST /F / 148A/2024-25/106427 4258( 1); and impugned notice u/s 148 dated 22.04.2024 bearing no. ITBA/AST/S/148_1/2024-25/1064274383(1); issued by the Respondents to the Petitioner for AY 2020-21 and all proceedings emanating therefrom in consequence;” 2. In effect, the petitioner is challenging notice issued under Section 148(b) dated 23.03.2024; order under Section 148A(d) dated 22.04.2024 and notice under Section 148 dated 22.04.2024. We find that thereafter further notices have been issued as can be seen from the petition dated 15.10.2025, 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 29/12/2025 at 11:45:01

which is a notice under Section 143 (2); notice under Section 141, under Section 142 (1) dated 29.05.2025, 28.08.2025 followed by reminder letters dated 15.09.2025 and 03.10.2025. 3. Having noted the fact that even subsequent communications have been issued but the challenge is only confined to the notice issued under Section 148A(b); order passed under Section 148A(d) and notice under Section 148 of the Act, we are of the view that the challenge in the petition only to the aforesaid three communications is untenable, more so when those notices/order were issued in the month of April, 2024 that is almost 1½ years back. It is quite late in the day for making a challenge to the same. 4. The petition is dismissed. V. KAMESWAR RAO, J VINOD KUMAR, J DECEMBER 23, 2025 cd 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 29/12/2025 at 11:45:01

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