$~10 * IN THE HIGH COURT OF DELHI AT NEW DELHI + W.P.(C) 7372/2026, CM APPL. 35902/2026 & CM APPL. 35903/2026 MANCHANDA HERBAL PRODUCTS PRIVATE LIMITED .....Petitioner Through: Mr. Kaushik and Mr. Ram Naresh, Advocates. versus UNION OF INDIA THROUGH SECRETARY OF FINANCE & ANR. .....Respondents Through: Mr. Anil Panwar, SPC with Ms. Rakshita Goyal, Mr. Nikhil Goel and Mr. Sahej Sawhney, Advocates for R- 1/UOI. Mr. Gaurav Gupta, SSC with Mr. Shivendra Singh, JSC, Mr. Yojit Pareek, JSC and Ms. Aryama Singh Rajput, Advocate for R-2/Income Tax Dept. CORAM: HON'BLE MR. JUSTICE DINESH MEHTA HON'BLE MR. JUSTICE RAJNEESH KUMAR GUPTA O R D E R % 08.07.2026 1. By way of the present writ petition, the petitioner has challenged the order dated 29.06.2025 and the corresponding notice of even date passed/issued under Section 148 of the Income Tax Act, 1961 (hereinafter referred as to ‘the Act’). 2. Having heard the learned Counsel for the petitioner and going through the record, we do not find the notice under challenge to be without jurisdiction. Further, a perusal of the notice and reasons enclosed therewith 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 10/07/2026 at 11:49:11 shows that the Assessing Officer (hereinafter referred to as ‘AO’) has a reasonable basis to proceed against the petitioner. The arguments which learned Counsel for the petitioner has advanced before us, may or may not have a bearing on the quantum of addition (if made), but by this reason itself, the notice issued by the AO cannot be alleged to be without jurisdiction so as to warrant interference by us. 3. The petitioner may file a reply and canvass his submissions and defence including contention in light of proviso I to Section 56(x) of the Act before the AO, which shall be objectively considered by the AO. 4. The petition is, therefore, dismissed without making any observations on merits. All the pending applications stand disposed of. DINESH MEHTA, J. RAJNEESH KUMAR GUPTA, J. JULY 8, 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 10/07/2026 at 11:49:11