RUDRA ALLOYS PRIVATE LIMITED vs. ASSISTANT COMMISSIONER OF INCOME TAX

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CWP/21009/2025HC Punjab & HaryanaPHHC01114664202515 September 2026Author: MR. JUSTICE SUNISH BINDLISH,MR. JUSTICE DEEPAK SIBAL1 pages
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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?

Section 148

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

15.09.

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

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