$~5 * IN THE HIGH COURT OF DELHI AT NEW DELHI % Date of Decision : 08.10.2025 + W.P.(C) 15078/2025 CM APPL. 62033/2025 FERRA ENGINEERING PTY LIMITED .....Petitioner Through: Mr. Kamal Sawhney, Mr. Nikhil Agarwal, Mr. and Mr. Nishank Vahistha, Advs.

versus ASSISTANT COMMISSIONER OF INCOME TAX, CIRCLE INTERNATIONAL TAXATION-1-3-1, DELHI .....Respondent Through: Mr. Vipul Agrawal (Sr. SC) with Ms.

Sakshi Shairwal, Mr. Akshat Singh (Jr. SCs), Mr. Gaoraang Ranajn and Ms. Harshita Kotru (Advs.).

CORAM:

HON'BLE MR. JUSTICE V. KAMESWAR RAO HON'BLE MR. JUSTICE VINOD KUMAR V. KAMESWAR RAO , J. (ORAL)

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

“(a) Issue a writ of certiorari, or any other appropriate writ or order quashing the Impugned Section 148A(1) Notice dated 29.03.2025 as well as Impugned Order issued under Section 148A(3) and the Impugned Notice issued under Section 148, both dated 30.06.2025, and all the consequential proceedings.

(b) For such further and other reliefs, including costs of this Petition, as this Hon’ble Court may deem fit and proper in the nature and circumstances of the case.

(c) Award the costs of this Writ Petition in favour of the Petitioner and against Re