Reassessment Upheld as Section 148 Notice Issued Within Limitation Despite clerical error in email attachment

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 0

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