Facts of the Case
Alankit Forex India Limited, along with numerous
connected entities and individuals, filed writ petitions before the Delhi High
Court challenging income-tax proceedings initiated following search and
investigation actions. Subsequent to the search, jurisdiction over the
petitioners’ cases was transferred to the Central Circle of the Income Tax
Department.
Pursuant to such transfer, the Deputy Commissioner
of Income Tax, Central Circle-28, Delhi issued various notices initiating
assessment and related proceedings. The petitioners contested these actions,
alleging absence of jurisdiction and non-compliance with statutory
requirements. The matters were heard together as part of a batch of connected
cases involving multiple petitioners arising out of the same investigative
context.
Issues Involved
- Whether the transfer of jurisdiction to Central Circle authorities
pursuant to search/investigation was legally valid.
- Whether notices initiating assessment or reassessment proceedings
were sustainable in law.
- Whether the Income Tax Department complied with statutory
preconditions before issuing such notices.
- Whether the High Court should exercise writ jurisdiction to quash
proceedings at the preliminary stage.
Petitioner’s Arguments
- The petitioners contended that the impugned notices and proceedings
were issued without lawful jurisdiction.
- It was argued that mandatory statutory conditions for initiating
assessment or reassessment proceedings had not been fulfilled.
- The transfer to the Central Circle and subsequent actions were
alleged to be arbitrary and violative of principles of natural justice.
- The petitioners sought quashing of the notices and restraint on further proceedings.
Respondent’s Arguments (Revenue)
- The Revenue submitted that the proceedings were initiated pursuant
to lawful search and investigation operations.
- Jurisdiction of the Central Circle authorities was validly assumed
under the provisions of the Income Tax Act, 1961.
- The Department argued that all procedural requirements had been
duly complied with.
- It was further contended that writ jurisdiction should not be
invoked at the notice stage, particularly where statutory remedies were
available.
Court Order / Findings
- Transfer of jurisdiction to the Central Circle following search
actions was within statutory authority.
- The notices initiating assessment proceedings were issued in
accordance with law.
- No jurisdictional error or patent illegality warranting
interference under Article 226 was demonstrated.
- Assessment proceedings could lawfully continue, and the petitioners could avail appropriate remedies under the statutory framework.
Important Clarification
- Courts ordinarily refrain from interfering at the stage of notice
where alternate statutory remedies exist.
- Post-search transfer of cases to Central Circle jurisdiction is
generally valid if supported by statutory provisions.
- Challenges to reassessment or assessment proceedings must establish
clear lack of jurisdiction, procedural illegality, or violation of natural
justice.
- The ruling reinforces the principle that disputed factual issues
should be adjudicated through the assessment and appellate process rather
than writ proceedings.
Link to
download the order – https://www.mytaxexpert.co.in/uploads/1772270237_ALANKITFOREXINDIALIMITEDVsDY.COMMISSIONEROFINCOMETAXCENTRALCIRCLE28DELHI.pdf
Disclaimer
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