FOREST HILL RESORT PRIVATE LIMITED vs. DEPUTY ASSISTANT COMMISSIONER OF INCOME TAX, CENTRAL 1, CHANDIGARH AND OTHERS

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CWP/30494/2026HC Punjab & HaryanaPHHC01157774202617 September 2026Author: MR. JUSTICE SUNISH BINDLISH,MR. JUSTICE DEEPAK SIBAL1 pages
AI SummaryAllowed

What did the High Court hold?

The High Court allowed the petition in terms of the judgment passed in Jyoti Sareen’s case dated 10.09.2026. Consequently, the notice dated 04.03.2024 issued to the petitioner under Section 148 of the Income Tax Act, 1961, and all consequential proceedings were quashed. The reasoning was based on the consensus between the learned counsel for the parties that the petitioner was entitled to the same relief as granted in the aforementioned Jyoti Sareen case. The operative direction was the quashing of the impugned notice and consequential proceedings. No issue was expressly left undecided.

What were the facts?

The petitioner, Forest Hill Resort Private Limited, challenged a notice dated 04.03.2024 issued under Section 148 of the Income Tax Act, 1961, along with any consequential proceedings. The respondent is the Deputy/Assistant Commissioner of Income Tax, Central 1, Chandigarh, and others. The case was heard by the High Court of Punjab & Haryana at Chandigarh. The parties agreed that the petitioner should receive the same relief as granted in a previous judgment by the same Court dated 10.09.2026 in CWP No.15791 of 2024, titled Jyoti Sareen Vs. Union of India and others.

What were the issues?

1. Whether the notice dated 04.03.2024 issued to the petitioner under Section 148 of the Income Tax Act, 1961, and consequential proceedings are liable to be quashed? The petitioner sought to quash the notice and proceedings. The revenue did not record any specific argument against the petitioner's claim, but agreed to the consensus reached by the parties. The core of the dispute, as implied by the reference to Jyoti Sareen's case, likely revolves around the validity of the reassessment proceedings initiated under Section 148, potentially concerning the satisfaction of conditions precedent for issuing such a notice.

Which sections of the Income-tax Act were involved?

Section 148

AI-generated summary — verify with the full judgment below

IN THE HIGH COURT OF PUNJAB & HARYANA AT CHANDIGARH

(Sr. No.152 )

CWP-30494-2026(O&M)

Date of decision : 17.09.2026 FOREST HILL RESORT PRIVATE LIMITED .....Petitioner

Versus

DEPUTY/ASSISTANT COMMISSIONER OF INCOME TAX, CENTRAL 1, CHANDIGARH AND OTHERS ` .....Respondent(s)

CORAM : HON'BLE MR. JUSTICE DEEPAK SIBAL

HON'BLE MR. JUSTICE SUNISH BINDLISH

Present : Mr. Rochak Singla, Advocate for the petitioner.

Mr. Ranvijay Singh, Senior Standing Counsel,

Mr. Vidul Kapoor, Junior Standing Counsel for

the respondent(s)-Income Tax Department.

* * * DEEPAK SIBAL, J. (Oral) (1) Learned counsel for the parties agree that the petitioner would also be entitled to the same relief as has been granted through a judgment of this Court dated 10.09.2026 passed in CWP No.15791 of 2024 - Jyoti Sareen Vs. Union of India and others. (2)

In the light of the above consensus, the petition is allowed in terms of Jyoti Sareen’s case (supra), resulting in quashing of the impugned notice dated 04.03.2024 issued to the petitioner under Section 148 of the Income Tax Act, 1961, along with consequential proceedings, if any. (3)

All pending miscellaneous applications, if any, also stand disposed of.

(DEEPAK SIBAL)

JUDGE

17.09.

2026

( SUNISH BINDLISH ) shamsher/sunil yadav

JUDGE

Whether speaking/reasoned : Yes / No Whether reportable

: Yes / No SHAMSHER SINGH 2026.09.18 16:45 I attest to the accuracy and integrity of this document Punjab and haryana high court, chandigarh

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