* IN THE HIGH COURT OF DELHI AT NEW DELHI % Judgment delivered on: 30.05.2025 + W.P.(C) 11198/2019 SANJAY KAUL .....Petitioner versus THE INCOME TAX OFFICER WARD 24 (4), NEW DELHI & ORS. .....Respondents Advocates who appeared in this case For the Petitioner : Mr. Deepak Kapoor, Advocate. For the Respondents : Ms. Hemlata Rawat, Advocate.

CORAM:

HON'BLE MR. JUSTICE VIBHU BAKHRU HON'BLE MR. JUSTICE TEJAS KARIA

JUDGMENT

TEJAS KARIA, J INTRODUCTION

1. The Petitioner has filed the present petition under Article 226 read with Article 227 of the Constitution of India, impugning a notice dated 30.03.2019 [impugned notice] issued by the Respondent No.1 under Section 148 of the Income Tax Act, 1961 [the Act] in respect of Assessment Year [AY] 2014-15.

2. By way of the present petition, the Petitioner has essentially challenged the action of the Respondent No.1 to reopen the proceedings for AY 2014-15. It is the petitioner‟s case that the Respondent No.1 did not have any reason to believe that the petitioner‟s income for the AY 2014-15 had escaped assessment and that the impugned notice was issued merely based on conjecture and surmises as opposed to any tangible material.

FACTUAL BACKGROUND

3. Th