$~32 * IN THE HIGH COURT OF DELHI AT NEW DELHI % Date of Decision : 16.01.2026 + W.P.(C) 578/2026 CM APPL.2864/2026 CM APPL.2865/2026 EXPRESS FREIGHT CONSORTIUM .....Petitioner Through: Mr. Nageswar Rao, Mr. Parth and Mr.

Ravilochan Daliparthi, Advs.

versus ASSESSMENT UNIT, INCOME-TAX DEPARTMENT & ORS.

.....Respondents Through: Mr. Gaurav Gupta, SSC.

CORAM:

HON'BLE MR. JUSTICE DINESH MEHTA HON'BLE MR. JUSTICE VINOD KUMAR

JUDGMENT

DINESH MEHTA, J. (ORAL)

1. By way of the present writ petition, the petitioner has challenged the final assessment order and corresponding demand notice which the Assessing Officer (hereinafter referred to as ‘AO’) has passed on

18.12.2025, without affording an opportunity of hearing to the petitioner.

2. Apprising the facts briefly, learned counsel for the petitioner submitted that draft assessment order was passed on

06.11.2025, whereafter, the petitioner filed objections before the Dispute Resolution Panel (hereinafter referred to as ‘DRP’) on 05.12.2025. It is admitted that a copy thereof was not sent to the AO, bonafidely believing that the DRP shall forward the same to him.

3. While admitting that the assessee did receive a notice from the AO on 08.12.2025, the