$~66 * IN THE HIGH COURT OF DELHI AT NEW DELHI + W.P.(C) 17885/2025 TMEN SYSTEMS PRIVATE LIMITED THROUGH AUTHORIZED REPRESENTATIVE .....Petitioner Through: Ms. Divyanshi Singh and Mr. Dhruv Dev Gupta, Advs.

versus ASSISTANT COMMISSIONER OF INCOME TAX, CIRCLE 25 -1, DELHI AND ORS.

.....Respondent Through: Mr. Siddhartha Sinha, SSC and Mr.

Nring Chamwibo Zeliang, Adv.

CORAM:

HON'BLE MR. JUSTICE V. KAMESWAR RAO HON'BLE MR. JUSTICE VINOD KUMAR

O R D E R

% 26.11.2025

1. The matter is taken up today as the date fixed, i.e. 25.11.2025 was declared a holiday pursuant to Notification No.35/G-4/Genl-I/DHC dated

24.11.2025, issued by this Court.

2. This petition has been filed with the following prayers :

“a. Issue writ, order or direction in the nature of certiorari or any other appropriate writ, order or direction to quash and set aside the impugned Notices dated 21.03.2024 issued under Section 148A(b) of ITA, 1961 by Respondent No. 1 reopening assessment for AY 2020-21, without authority and jurisdiction, in violation of provisions of the Income Tax Act, 1961 and that of principles of natural justice and in violation of Article 14, 19(1)(g), 265 and 300A of the Constitution of India; b. Issue writ,