$~20 * IN THE HIGH COURT OF DELHI AT NEW DELHI % Date of Decision: 07.07.2025 + W.P.(C) 1155/2024 & CM No.4824/2024 BABA GLOBAL LTD .....Petitioner Through: Mr. Ved Jain, Mr. Nischay Kantoor & Ms. Soniya Dodeja, Advs.

Versus ASSISTANT COMMISSIONER OF INCOME TAX, CENTRAL CIRCLE 29 & ORS. .....Respondents Through: Mr. Shlok Chandra, Ms. Nancy Jain, and Ms. Madhavi Shukla, Advs.

CORAM:

HON'BLE MR. JUSTICE VIBHU BAKHRU HON'BLE MR. JUSTICE TEJAS KARIA VIBHU BAKHRU, J. (ORAL

1. The petitioner [Assessee] has filed the present petition, inter alia impugning the following notices/orders:

(i) Notice dated 31.03.2023 issued under Section 148A(b) of the Income Tax Act, 1961 [the Act];

(ii) Corrigendum letter dated 28.04.2023;

(iii) Order dated 27.04.2023 under Section 148(d) of the Act sent by e-mail dated 28.04.2023 at 12:31 AM; and (iv) Notice dated 27.04.2023 sent by e-mail dated 28.04.2023 at

12:08 AM.

2. It is the petitioner’s case that the notice dated 27.04.2023 issued under Section 148 of the Act [impugned notice] for Assessment Year [AY

2019-20 is invalid as it was issued beyond the period of limitation. The last date for issuance of the notice was 31.03.2023. After accounting for the exclusio