Full Judgment Text
$~11
* IN THE HIGH COURT OF DELHI AT NEW DELHI
th
% Date of decision: 5 January, 2026.
+ W.P.(C) 22/2026
VEENA ARORA .....Petitioner
Through: Dr. Prince Mohan Sinha, Mr. Rajeev
Deora, Mr. Shiv Nath Bind, Advs.
versus
COMMISSIONER INCOME TAX - 12 DELHI & ANR.
.....Respondents
Through: Mr. Indruj Singh Rai, Sr. Standing
Counsel with Mr. Sanjeev Menon,
Mr. Rahul Singh, Mr. Gaurav Kumar,
Advs.
CORAM:
HON'BLE MR. JUSTICE DINESH MEHTA
HON'BLE MR. JUSTICE VINOD KUMAR
J U D G M E N T
DINESH MEHTA, J. ( Oral )
1. By way of present writ petition, the petitioner has challenged notice
under Section 148 of Income Tax Act, 1961 issued on 28.03.2025.
2. Learned counsel for the petitioner argued that the impugned notice is
arbitrary and without any basis.
3. Inviting Court’s attention towards Annexure A-2 appended to the
aforesaid notice, he asserted that except for the excel sheet, which was found
at premises of ‘Bhutani Infra Group and Associates’ in which the
petitioner’s name reflecting a cash transaction of Rs.7,97,991/- was
mentioned, there is no other material. It was argued that unless the
Assessing Officer is able to establish a link of the petitioner with that
transaction or is able to bring on record any other incriminating material, he
cannot proceed against the petitioner.
Signature Not Verified
Digitally Signed
By:NAVEEN KUMAR
Signing Date:07.01.2026
10:35:32
W.P.(C) 22/2026 Page 1 of 2
4. During the course of submissions, pursuant to Court’s query, learned
counsel admitted the factum of petitioner’s purchasing a flat from said
group. He, nevertheless, argued that simply because the petitioner had
purchased a flat from the said builder, reassessment proceeding against her
cannot be initiated.
5. Having heard, learned counsel for the petitioner, we are of the
considered view that the material, which has been relied upon by the
Assessing Officer, is enough to infer escapement of income of the
petitioner-assessee in the relevant assessment year. Language of section 148
of the Income Tax Act after 01.04.2021, does not even require recording
reason to believe much less possession of information or evidence.
6. Be that as it may. It is for the petitioner to satisfy the concerned
authority that the basis is erroneous or that she has no nexus with the
amount, which has been shown by the said Bhutani Infra Group and
Associates.
7. The notice cannot be said to be without jurisdiction or otherwise void.
8. Hence, the writ petition is dismissed.
9. Needless to mention that any observations made herein may not
influence or affect the rights of either of the parties and the petitioner shall
be free to put up her case before the respondents in accordance with law.
DINESH MEHTA
(JUDGE)
VINOD KUMAR
(JUDGE)
JANUARY 5, 2026/ ck
Signature Not Verified
Digitally Signed
By:NAVEEN KUMAR
Signing Date:07.01.2026
10:35:32
W.P.(C) 22/2026 Page 2 of 2