Delhi High Court
W.P.(C)/15635/2025 of KAIROSOFT AI SOLUTIONS LIMITED FORMERLY PANKAJ PIYUSH TRADE AND INVESTMENT LIMITED Vs ASSISTANT COMMISSIONER OF INCOME TAX CENTRAL CIRCLE 31 DELHI & ANR. on 29 September 2026
HIGH COURT OF DELHI AT NEW DELHI # CNR No. DLHC010778652025 + W.P.(C) 15635/2025 & CM APPL. 63958/2025 KAIROSOFT AI SOLUTIONS LIMITED FORMERLY PANKAJ PIYUSH TRADE AND INVESTMENT LIMITED .....Petitioner Through: Mr. Anmol Jagga, Ms. Shagun Runil & Mr. Karan Chopra, Advocates. versus
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IN THE HIGH COURT OF DELHI AT NEW DELHI
CNR No. DLHC010778652025
+
W.P.(C) 15635/2025 & CM APPL. 63958/2025
KAIROSOFT AI SOLUTIONS LIMITED FORMERLY PANKAJ
PIYUSH TRADE AND INVESTMENT LIMITED .....Petitioner Through:
Mr. Anmol Jagga, Ms. Shagun Runil
& Mr. Karan Chopra, Advocates.
versus
ASSISTANT COMMISSIONER OF INCOME TAX CENTRAL
CIRCLE 31 DELHI & ANR.
.....Respondents
Through:
Mr. Shlok Chandra, SSC with Ms.
Naincy Jain, JSC, Ms. Madhavi
Shukla, JSC & Mr. Udit Dad, Adv.
CORAM:
HON'BLE MR. JUSTICE DINESH MEHTA
HON'BLE DR. JUSTICE ADITI CHOUDHARY
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O R D E R
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29.09.2026
1. Mr. Anmol Jagga, learned counsel for the petitioner, invited Court’s attention towards the remand order passed by Hon’ble the Supreme Court on 04.05.2026 more particularly, paragraph no.5 thereof and submitted that the assessment year in question is 2015-16 and in view of paragraph no.19(f) of the judgment of Hon’ble the Supreme Court in the case of Union of India & Ors. v. Rajeev Bansal reported in 2024 SCC OnLine SC 2693, the reassessment proceedings under Section 148 of the Income Tax Act, 1961 (hereinafter referred to as ‘the Act of 1961’) are liable to be declared time-barred. 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 01/10/2026 at 12:09:15
2. Ms. Naincy Jain, learned Junior Standing Counsel, is not in a position to dispute the aforesaid position of the facts and law.
3. In view of the aforesaid, the writ petition is allowed. The impugned notice dated 31.08.2024 (annexure P-3) issued under Section 148 of the Act of 1961 and impugned order (annexure P-2) of even date passed under Section 148A(d) of the Act of 1961 for assessment year 2015-16 are hereby quashed. DINESH MEHTA, J. ADITI CHOUDHARY, J. SEPTEMBER 29, 2026/nk 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 01/10/2026 at 12:09:15