"$~28 * IN THE HIGH COURT OF DELHI AT NEW DELHI + W.P.(C) 7600/2023 BRIJ MOHAN GOYAL(HUF) .....Petitioner Through: Mr. Akash Ojha and Ms. Cauvery Rawal, Advocates. versus UNION OF INDIA AND ANR. .....Respondents Through: Mr. Shlok Chandra, SSC with Ms. Naincy Jain, JSC. CORAM: HON'BLE MR. JUSTICE DINESH MEHTA HON'BLE MR. JUSTICE VINOD KUMAR O R D E R % 19.01.2026 1. The present petition challenges the notice dated 29.07.2022 which has been issued under Section 148 of the Income Tax Act, 1961 for the Assessment Year 2015-16. 2. Learned counsel for the petitioner submitted that the same is clearly time barred in light of judgment of Hon’ble the Supreme Court rendered in the case of Union of India & Ors. v. Rajeev Bansal [2024] 167 taxmann.com 70 (SC) followed by this Court in the case of Makemytrip India (P.) Ltd. v. Deputy Commissioner of Income-tax Circle 16(1) Delhi & Anr. reported in (2025) 173 taxmann.com 497 (Delhi). 3. Ms. Naincy Jain, learned Junior Standing Counsel appearing for the respondents is not in a position to dispute the aforesaid position of facts and law. This is a digitally signed order. The authenticity of the order can be re-verified from Delhi High Court Order Portal by scanning the QR code shown above. The Order is downloaded from the DHC Server on 22/01/2026 at 13:22:43 Printed from counselvise.com 4. Having heard learned counsel for the parties and considering paragraph no. 8 of the judgment in case of Makemytrip India (p.) Ltd (supra), we are of the considered opinion that the impugned notice in the present writ petition is barred by limitation and thus, without jurisdiction. 5. Notice dated 29.07.2022 and any proceeding in furtherance thereof are hereby quashed. 6. The instant petition is, therefore allowed and disposed of in aforesaid terms. DINESH MEHTA, J. VINOD KUMAR, J. JANUARY 19, 2026/MR This is a digitally signed order. The authenticity of the order can be re-verified from Delhi High Court Order Portal by scanning the QR code shown above. The Order is downloaded from the DHC Server on 22/01/2026 at 13:22:43 Printed from counselvise.com "