No Reassessment under Income Tax Act on Identical Issue: Delhi HC Quashes Order Against Logix Heights [Read Order]
The court agreed that reassessment proceedings could not be initiated for a matter already examined by the department.
![No Reassessment under Income Tax Act on Identical Issue: Delhi HC Quashes Order Against Logix Heights [Read Order]](https://images.taxscan.in/h-upload/2025/11/08/2103433-no-reassessment-income-tax-act-identical-issue-delhi-hc-logix-heights-taxscan.webp "No Reassessment under Income Tax Act on Identical Issue: Delhi HC Quashes Order Against Logix Heights [Read Order]")
In the case of Logix Heights Private Limited, the Delhi High Court has set aside an income tax reassessment notice and order, holding that reassessment proceedings cannot be initiated for an issue that has already been examined and decided by the tax department. Logix Heights Private Limited, the petitioner, filed a writ petition challenging a notice dated 29.03.2025 issued under...
In the case of Logix Heights Private Limited, the Delhi High Court has set aside an income tax reassessment notice and order, holding that reassessment proceedings cannot be initiated for an issue that has already been examined and decided by the tax department.
Logix Heights Private Limited, the petitioner, filed a writ petition challenging a notice dated 29.03.2025 issued under Section 148A(1) and a subsequent order and notice dated 30.06.2025 under Sections 148A(3) and 148 of the Income Tax Act, 1961, for the Assessment Year 2019-20.
Delhi HC Sets aside Income Tax Reassessment Notice against Michael and Susan Dell Foundation [Read Order]
Counsel for the petitioner argued that the reassessment was initiated based on alleged non-genuine transactions with M/s Mekaster Finlease Limited. However, the petitioner contended that this identical issue had already been examined in a prior reassessment proceeding for the same assessment year, culminating in an order dated 17.03.2025 where the transactions were treated as 'accommodation entries' and an addition was made. It was emphasized that the Assessing Officer (AO) failed to consider this specific plea in the impugned order.
Don’t Let Your Income Get Clubbed! Understand the hidden rules now! Click here
The counsel for the Revenue did not contest the petitioner's contention that the issue was identical to one previously decided.
A division bench comprising Justice V. Kameswar Rao and Justice Vinod Kumar noted that the AO had not addressed the petitioner's specific plea regarding the prior assessment on the same issue. The court agreed that reassessment proceedings could not be initiated for a matter already examined by the department.
Accordingly, the court set aside the impugned order under Section 148A(3) and the notice under Section 148. The matter was remanded back to the AO, who was directed to provide the petitioner with a proper opportunity of being heard, allow the submission of relevant documents, and pass a fresh, reasoned order. The court stipulated that this exercise be completed within eight weeks.
Support our journalism by subscribing to Taxscan premium. Follow us on Telegram for quick updates
