KRISHAN LAL GARG vs. INCOME TAX OFFICER AND OTHERS

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CWP/25808/2025HC Punjab & HaryanaPHHC01140011202514 September 2026Author: MR. JUSTICE SUNISH BINDLISH,MR. JUSTICE DEEPAK SIBAL1 pages
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What did the High Court hold?

The High Court held that in light of the consensus between the parties and following the precedent set in the case of Jyoti Sareen vs. Union of India and others (CWP-15791-2024, decided on 10.09.2026), the petition should be allowed. The Court found that the petitioner would be entitled to the same relief as granted in the Jyoti Sareen case. Consequently, the impugned notice dated 19.05.2025 issued to the petitioner under Section 148 of the Income Tax Act, 1961, and any consequential proceedings were quashed. The Court did not explicitly leave any issue undecided.

What were the facts?

The petitioner, Deepak Sibal, filed a writ petition before the High Court of Punjab and Haryana. The petition challenged an action taken by the Revenue, specifically the issuance of a notice under Section 148 of the Income Tax Act, 1961, and any consequential proceedings. The assessment year(s) are not explicitly stated but the notice under Section 148 implies reassessment proceedings. The procedural history indicates that the parties agreed to a consent order. The High Court considered a previous judgment in CWP-15791-2024, Jyoti Sareen vs. Union of India and others, dated 10.09.2026, which granted similar relief. The impugned notice was dated 19.05.2025.

What were the issues?

1. Whether the impugned notice issued under Section 148 of the Income Tax Act, 1961, and consequential proceedings are liable to be quashed. (Question of law and fact) Assessee's contention: The assessee argued that the impugned notice and consequential proceedings should be quashed. This contention is based on the agreement reached by the parties and the precedent set in the case of Jyoti Sareen vs. Union of India and others. Revenue's contention: The Revenue, through its counsel, agreed with the assessee's submission and consented to the relief sought. They did not present any arguments against the quashing of the notice and proceedings.

Which sections of the Income-tax Act were involved?

Section 148

AI-generated summary — verify with the full judgment below

240 240 240 240

IN T IN T IN T IN T KRISHAN LA KRISHAN LA KRISHAN LA KRISHAN LA INCOME TAX INCOME TAX INCOME TAX INCOME TAX

CORAM: CORAM: CORAM: CORAM: HO HO

HO HO

Present : M M M

M M for **

DEEPAK SIB DEEPAK SIB DEEPAK SIB DEEPAK SIB

1.

Le also be entitled this Court date Union of India

2.

In terms of Jyoti notice dated 1 Income Tax Ac

14.

09 14.09 14.09 14.09.2026 .2026 .2026 .2026 Vandana yadav

THE HIGH COURT OF PUNJA THE HIGH COURT OF PUNJA THE HIGH COURT OF PUNJA THE HIGH COURT OF PUNJA AT CHANDIGARH AT CHANDIGARH AT CHANDIGARH AT CHANDIGARH

CW CW CW CW Da Da Da Da

AL GARG AL GARG AL GARG AL GARG

VERSUS VERSUS VERSUS VERSUS X OFFICER AND OTHERS X OFFICER AND OTHERS X OFFICER AND OTHERS X OFFICER AND OTHERS ON'BLE MR. JUSTICE ON'BLE MR. JUSTICE ON'BLE MR. JUSTICE ON'BLE MR. JUSTICE DEEP DEEP DEEP DEEP ON’BLE MR. JUSTICE SUNI ON’BLE MR. JUSTICE SUNI ON’BLE MR. JUSTICE SUNI ON’BLE MR. JUSTICE SUNI Mr. Vishav Bharti Gupta, Advocat s. Ubhai Bharti Gupta, Advocate Ms. Mamta Gupta, Advocate, for t Mr. Saurabh Kapoor, Sr. Standing Mr. Rana Gurtej Singh, Jr. Standin r the respondents.

*** BAL AL BAL AL, J. , J. , J. , J.(O (O (O (Oral ral ral ral) earned counsel for the parties a d to the same relief as has been ed 10.09.2026 passed in CWP- a and others. n the light of the above consen i Sareen’s case (supra), resulting 19.05.2025 issued to the petitio ct, 1961 alongwith consequential

Whether speaking/reasoned. : Ye Whether Reportable. : Ye

AB AND HARYANA AB AND HARYANA AB AND HARYANA AB AND HARYANA H WP WP WP WP-25808 25808 25808 25808-2025 2025 2025 2025 ate of Decision : ate of Decision : ate of Decision : ate of Decision : 14.09. 14.09. 14.09. 14.09.2026 2026 2026 2026

...PETITIONER ...PETITIONER ...PETITIONER ...PETITIONER

...RESPONDENTS ...RESPONDENTS ...RESPONDENTS ...RESPONDENTS PAK SIBAL PAK SIBAL PAK SIBAL PAK SIBAL ISH BINDLISH ISH BINDLISH ISH BINDLISH ISH BINDLISH te, e and the petitioner. Counsel with ng Counsel, agree that the petitioner would n granted through a judgment of -15791-2024 – Jyoti Sareen vs. nsus, the petition is allowed in g in quashing of the impugned oner under Section 148 of the l proceedings, if any. (DEEPAK SIBAL DEEPAK SIBAL DEEPAK SIBAL DEEPAK SIBAL)

JUDGE JUDGE JUDGE JUDGE (SUNISH BINDLISH) (SUNISH BINDLISH) (SUNISH BINDLISH) (SUNISH BINDLISH)

JUDGE JUDGE JUDGE JUDGE es/No es/No d f . n d e VANDANA YADAV 2026.09.17 12:00 I attest to the accuracy and integrity of this document

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