Logix Heights Private Limited Vs DCIT (Delhi High Court)
In the case of Logix Heights Private Limited vs. Deputy Commissioner of Income Tax (Delhi High Court), the petitioner challenged a notice dated 29 March 2025 issued under Section 148A(1) of the Income-Tax Act, 1961, for Assessment Year 2019-20, as well as an order dated 30 June 2025 under Section 148A(3) and a consequential notice under Section 148 of the Act for the same year. The petitioner’s primary contention was that the Assessing Officer (AO) had reopened the case on the basis of alleged non-genuine transactions with a party (M/s. Mekaster Finlease Limited) to the tune of ₹ 27,72,53,102/-, despite the fact that those same transactions had already been the subject of reassessment under Section 147 r.w.s. 144B in March 2025, leading to an assessment at ₹ 25,02,16,448/-. The petitioner argued that the AO had not considered its detailed reply and supporting documents (including ITRs, bank statements and confirmation of the counterparty) in the impugned order under Section 148A(3), and that reassessment cannot be initiated under Section 148 on an issue already examined under earlier assessment proceedings. The Revenue did not contest the petitioner’s contention regarding non-consideration of the plea. The Court directed that the impugned Section 148A(3) order and Section 148 notice dated 30 June 2025 be set aside and remanded the matter to the AO. The AO is to afford the petitioner a fresh hearing, allow submission of documents, and pass a fresh, reasoned order within eight weeks. The petition is disposed accordingly.
