The Delhi High Court will soon to decide whether the tax department can retrospectively reopen old tax notices involving foreign assets—even if those notices were time-barred under earlier rules. A division bench led by Justices Vibhu Bakhru and Tejas Karia was hearing a batch of petitions on 30 May – filed by companies such as UK Paints (Overseas) Ltd, BJN Holdings (India) Ltd, and KS Dhingra – challenging these reassessment notices under Section 148 of the Income Tax Act. It referred the matter to a larger bench for a final decision. The notices were issued between 2014 and 2021, covering assessment years that stretch back decades.