Pawan Sachdeva Vs ITO (Delhi High Court)
The Delhi High Court dismissed a writ petition challenging the continuation of reassessment proceedings for Assessment Year 2012–13. The petitioner had assailed an order dated 30.12.2025 by which his objection to jurisdiction was rejected and reassessment proceedings were allowed to continue.
The petitioner had originally filed his return on 26.09.2012 declaring income of ₹9,39,990. On 31.03.2019 at 11:07 pm, an email was sent to his registered email ID from the office of the Assessing Officer. The petitioner viewed the email on 01.04.2019. However, the document attached bore the name and PAN of another assessee, M/s Paramsant Global Infratech Ltd. The petitioner informed the department on 18.04.2019 that the notice pertained to a third party. On 05.09.2019, the reasons for reopening were forwarded to him. He raised objections on the ground that no valid notice under Section 148 of the Income Tax Act, 1961 had been issued or served within limitation.
Despite his objections, a notice under Section 142(1) was issued on 18.10.2019, and further communications followed. An assessment order dated 12.12.2019 was passed under Sections 144 read with 147, making an addition of ₹13,00,000 and assessing total income at ₹22,39,990. On appeal, the Commissioner of Income Tax (Appeals) set aside the assessment on 12.12.2024 and remanded the matter to examine the validity of the notice. Subsequently, the impugned order dated 30.12.2025 rejected the petitioner’s objections.
