RUDRA ALLOYS PRIVATE LIMITED vs. ASSISTANT COMMISSIONER OF INCOME TAX
What did the High Court hold?
The High Court of Punjab & Haryana at Chandigarh allowed the petition in terms of the judgment in Jyoti Sareen Vs. Union of India and others (CWP No.15791 of 2024). Consequently, the notice dated 28.06.2025 issued to the petitioner under Section 148 of the Income Tax Act, 1961, and any consequential proceedings were quashed. The Court noted a consensus between the parties that the petitioner would be entitled to the same relief as granted in the aforementioned case. The reasoning is based on the application of the precedent set by the Court in the Jyoti Sareen case. The operative direction is the quashing of the impugned notice and consequential proceedings. No issue was expressly left undecided.
What were the facts?
The petitioner, Rudra Alloys Private Limited, challenged a notice dated 28.06.2025 issued under Section 148 of the Income Tax Act, 1961, along with any consequential proceedings. The respondent is the Assistant Commissioner of Income Tax. 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. The assessment year(s) are not explicitly stated. The dispute amount is not mentioned.
What were the issues?
1. Whether the notice dated 28.06.2025 issued to the petitioner under Section 148 of the Income Tax Act, 1961, and consequential proceedings are liable to be quashed? (Question of law). Assessee's Contention: The petitioner argued that they are entitled to the same relief as granted in the case of Jyoti Sareen Vs. Union of India and others (CWP No.15791 of 2024), decided on 10.09.2026 by this Court. This implies that the grounds for challenging the Section 148 notice were similar to those in the cited case. Revenue's Contention: The revenue agreed with the petitioner that the same relief should be granted as in the Jyoti Sareen case. This indicates the revenue did not contest the application of the precedent to the present case.
Which sections of the Income-tax Act were involved?
AI-generated summary — verify with the full judgment below
IN THE HIGH COURT OF PUNJAB & HARYANA AT CHANDIGARH
(Sr. No.251 )
CWP-21009-2025 (O&M)
Date of decision : 15.09.2026
RUDRA ALLOYS PRIVATE LIMITED .....Petitioner
Versus
ASSISTANT COMMISSIONER OF INCOME TAX ` .....Respondent(s)
CORAM : HON'BLE MR. JUSTICE DEEPAK SIBAL
HON'BLE MR. JUSTICE SUNISH BINDLISH
Present : Mr. Salil Dev Singh Bali, Senior Advocate with
Ms. Simmy Gupta, Advocate for the petitioner.
Mr. Saurabh Kapoor, Senior Standing Counsel and
Mr. Rana Gurtej Singh, Junior Standing Counsel for
the respondent-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 28.06.2025 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
2026
( SUNISH BINDLISH ) sunil yadav
JUDGE
Whether speaking/reasoned : Yes / No Whether reportable : Yes / No SUNIL YADAV 2026.09.17 16:12 I attest to the accuracy and authenticity of this order. Chandigarh
More judgments on Section 148
- ACIT Central Bilaspur, Bilaspur vs Arun Kumar Agrawal, SaktiITSSA 26/RPR/2025[2018-19]Status: Disposed21 Oct 2026AY 2018-19
- Vinod Agrawal, Kawardha vs Assisstant Commissioner of Income Tax…ITA 666/RPR/2026[2019-20]Status: Heard21 Oct 2026AY 2019-20
- Sar Business Tradelink Private Limited… vs Income Tax Officer, Ward - 1(2), RaipurITA 599/RPR/2026[2014-15]Status: Heard21 Oct 2026AY 2014-15
- Neo Incorporation, Rajkot vs DCIT Circle- 1(2), RajkotITA 471/RJT/2026[2012-2013]Status: Disposed21 Oct 2026AY 2012-2013
- Adj Agri International LLP, Rajkot vs The Income Tax Officer, Ward-1(1)(1), RajkotITA 1198/RJT/2026[2018-19]Status: Disposed21 Oct 2026AY 2018-19
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