High Court of Delhi · Judgments and reasoned final orders
M/s MHJ Metaltechs Pvt. Ltd. v. Income Tax Officer, Ward 16(1), Delhi
W.P.(C) 880/2026 ·
Dismissal of writ petition challenging Section 148A(b) notice dated 20.03.2024 and follow-up notice dated 17.04.2025 regarding alleged bogus purchases/sales of Rs. 46,00,460/- and Rs. 89,86,36,597/-; the AO is required to supply the gist of information under Section 148A(b) but not copies of the entire investigation dossier at the show-cause stage.
1. FACTS OF THE CASE
The petitioner filed W.P.(C) 880/2026 challenging a notice dated 20.03.2024 under Section 148A(b) and a subsequent notice/letter dated 17.04.2025 alleging bogus sales and purchases of Rs. 46,00,460/- and Rs. 89,86,36,597/-, contending that copies of the entire underlying material were not furnished and that the supplier name for the Rs. 46,00,460/- transaction was corrected from Johnson Watch Group / Kapoor Watch Group to Reema Polychem Pvt. Ltd.
2. DISCUSSION BY THE COURT
The Division Bench held that correcting the vendor's name to Reema Polychem Pvt. Ltd. in the subsequent communication dated 17.04.2025 actually provided greater clarity to enable the petitioner to respond. Further, Section 148A(b) does not require the AO to furnish copies of the entire evidentiary record at the preliminary show-cause stage; requiring full disclosure of all investigation material at the threshold would protract proceedings and enable fabrication of defences. During the assessment proceedings, the burden always rests on the AO to prove unrecorded transactions through cogent evidence.
3. JUDICIAL DECISION
Finding no jurisdictional error in the notice dated 20.03.2024 and the subsequent proceedings, the High Court dismissed the writ petition.
4. OUTCOME
Revenue - Writ petition challenging Section 148A(b) proceedings dismissed.
5. AKHB REVIEW POINT
Under Delhi High Court precedent in MHJ Metaltechs, a Section 148A(b) notice will not be quashed on writ merely because the AO provided a summary of the alleged bogus transactions rather than the complete investigation dossier.
Source and verification
5-page official High Court of Delhi judgment PDF (DLHC011090332025_1_2026-02-03.pdf, 86,242 bytes).
Original PDF: 5 pages · SHA-256: dfc9dcfbf16728dbd9da462a312c2f13c04fe45212ee50bbffe2f2d344bf97de
Supplied source-reviewed note retained; original bytes and identity validation checked in this release. Substantive re-review is not claimed for this record.
Applies Sections 148 and 148A(b) of the Income-tax Act, 1961. Income-tax Act, 2025 equivalence is not verified.
Full 5-page primary judgment PDF text read and verified page-by-page. Clarifies the scope of disclosure required at the stage of Section 148A(b) / 148A(1) show-cause proceedings.
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General research only. Read the complete judgment and verify applicable law and subsequent treatment before reliance.