Kumar Santosh Vs PCIT & Ors (Delhi High Court)
Reassessment Proceedings Stayed
The Delhi High Court considered a petition challenging reassessment proceedings under Section 148 of the Income Tax Act, 1961. The petitioner stated that reassessment was initiated concerning insurance commission of Rs.90,64,748/- received from IFFCO-Tokio General Insurance Company Ltd., which was reflected in the petitioner’s return of income.
The petitioner submitted that despite providing a satisfactory reply, the Assessing Officer passed an order under Section 148A(3) and issued a Section 148 notice dated 29.06.2026.
Dispute Over Material Relied Upon
The Department submitted that page 122 referred to material relied upon, described as verification details attached, and contended that the document had not been attached by the petitioner.
The petitioner’s counsel stated that no document had been received apart from the annexures enclosed at pages 121 and 122 of the writ petition.
The Court issued notice. The Department accepted notice and was granted four weeks to file its reply, with four weeks thereafter for any rejoinder.
Interim Stay
The Delhi High Court directed that proceedings in furtherance of the Section 148 notice dated 29.06.2026 would remain stayed pending further proceedings. The matter was listed for 26.11.2026.
FULL TEXT OF THE JUDGMENT/ORDER OF DELHI HIGH COURT
