+ W.p.(C) 5056/2025 Cm Appl v. Assistant Commissioner Of Income Tax Circle International Taxation 1 2 2 Delhi Through

$~126 & 127 * IN THE HIGH COURT OF DELHI AT NEW DELHI (126) + W.P.(C) 5056/2025 CM APPL. 23211/2025 CM APPL. 23212/2025 ERNST AND YOUNG U.S. LLP .....Petitioner Through: Mr. Kamal Sawhney, Mr. Nikhil Agarwal & Mr. Nishank Vashistha, Advocates. versus ASSISTANT COMMISSIONER OF INCOME TAX CIRCLE INTERNATIONAL TAXATION 1 2 2 DELHI Through: .....Respondent (127) + W.P.(C) 5057/2025 CM APPL. 23213/2025 CM APPL. 23214/2025 ERNST AND YOUNG EMEIA SERVICES LIMITED .....Petitioner Through: Mr. Kamal Sawhney, Mr. Nikhil Agarwal & Mr. Nishank Vashistha, Advocates. versus ASSISTANT COMMISSIONER OF INCOME TAX CIRCLE INTERNATIONAL TAXATION 1 2 2 DELHI Through: .....Respondent CORAM: HON'BLE MR. JUSTICE VIBHU BAKHRUHON'BLE MR. JUSTICE TEJAS KARIA O R D E R % 22.04.2025 1. The petitioner has filed the present petitions, inter alia, impugning a notice dated 30.03.2025 issued under Section 148A(1) of the Income Tax Act, 1961 [the Act] for assessment year 2019-20. The petitioner has filed the present petitions, inter alia, impugning a 2.It is the Petitioners’ case that the said notice is premised on the same reason which was subject matter of examination by this court in W.P.(C) 7578/2023 captioned ERNST AND YOUNG U.S. LLP vs. ASSISTANT COMMISSIONER OF INCOME TAX as well as ERNST AND YOUNG EMEIA SERVICES LIMITED vs. ASSISTANT COMMISSIONER OF INCOME TAX CIRCLE-INTERNATIONAL TAX-1-2-2, DELHI: Neutral Citation 2025:DHC:2124-DB. 3.Considering that the impugned notice is in the nature of a show cause notice, we do not consider it apposite to entertain the present petitions. We, however, clarify that, in the event, the petitioner responds to the said notice within a period of one week from the date, the Assessing Officer shall consider the response as well as the decisions of this Court as mentioned above and pass an appropriate order. 4.In view of the above, the petitions alongwith all the pending applications are dismissed. applications are dismissed. 5.All rights and contentions of the parties are reserved. VIBHU BAKHRU, J APRIL 22, 2025/ ‘A’ TEJAS KARIA, J Click here to check corrigendum, if any