Amandeep Singh Vs ACIT (Delhi High Court)
Amandeep Singh (“the petitioner”) filed a writ petition before the Delhi High Court seeking to quash multiple notices and orders issued by the Income Tax Department for Assessment Year 2021-22, including notices under Sections 148 and 148A and an order under Section 148A(3) of the Income Tax Act, 1961 (“the Act”). The petitioner challenged the notices and orders on the grounds that successive notices issued under Section 148A relied on different “reasons to believe” and that the Income Tax authority had failed to establish any live nexus between the petitioner and the alleged transactions. He contended that the reassessment proceedings were initiated on incorrect and unfounded assumptions regarding his association with certain bank accounts and dummy or shell entities, and that the proceedings violated the provisions of Section 147 and settled judicial precedents.
The petitioner had filed his original return of income on 14 March 2022, declaring an income of ₹8,53,950. On 29 March 2025, the Revenue issued a notice under Section 148A(1), alleging that income had escaped assessment based on risk management analysis and purported links with dummy/shell entities and bank accounts. The petitioner responded on 7 April 2025, objecting to the basis of the notice, asserting that the bank accounts were not linked to him, the entities were not reflected in his GST returns, and the transactions were not unexplained. He requested that proceedings be dropped.
