HARMEET SINGH vs. INCOME TAX OFFICER

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CWP/6617/2024HC Punjab & HaryanaPHHC01034919202414 September 2026Author: MR. JUSTICE SUNISH BINDLISH,MR. JUSTICE DEEPAK SIBAL1 pages
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What did the High Court hold?

The High Court, in light of the consent of the parties and following the precedent set in Jyoti Sareen vs. Union of India and others (CWP-15791-2024), allowed the petition. The Court quashed the impugned notice dated 29.03.2023 issued to the petitioner under Section 148 of the Income Tax Act, 1961, and any consequential assessment proceedings. The reasoning was based on the agreement between the parties and the prior judgment. The ratio decidendi is that where parties consent and a clear precedent exists for similar relief concerning a Section 148 notice and consequential proceedings, the court should grant that relief. Any pending applications related to the matter were also to stand disposed of.

What were the facts?

The petitioner, Harmeet Singh, approached the High Court of Punjab and Haryana seeking relief similar to that granted in a previous case, CWP-15791-2024 (Jyoti Sareen vs. Union of India and others). The previous judgment, dated 10.09.2026, had granted relief to the petitioner in that case. The present petition was filed in light of this precedent and a notice dated 29.03.2023 issued to the petitioner under Section 148 of the Income Tax Act, 1961, along with consequential assessment proceedings. The parties agreed to a consent order.

What were the issues?

1. Whether the petitioner is entitled to the same relief as granted in Jyoti Sareen vs. Union of India and others (CWP-15791-2024)? (Question of law/mixed fact and law) Assessee's Contention: The assessee argued that they should be entitled to the same relief as granted in the precedent case of Jyoti Sareen. No specific authorities or provisions were mentioned in the judgment for the assessee's argument, beyond the reliance on the prior court order. Revenue's Contention: The revenue, represented by the respondents, agreed to the petitioner's request for similar relief. No specific arguments or reliance on authorities were recorded for the revenue.

Which sections of the Income-tax Act were involved?

Section 148

AI-generated summary — verify with the full judgment below

251 251 251 251

IN T IN T IN T IN T

HARMEET SI HARMEET SI HARMEET SI HARMEET SI INCOME TAX INCOME TAX INCOME TAX INCOME TAX

CORAM: CORAM: CORAM: CORAM: HO HO

HO HO

Present : M

M

M

fo **

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 2 Income Tax Ac

3.

Pe

14.

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

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

CW CW CW CW Da Da Da Da

INGH INGH INGH INGH

VERSUS VERSUS VERSUS VERSUS X OFFICER X OFFICER X OFFICER X OFFICER AND OTHERS AND OTHERS AND OTHERS 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. ON’BLE MR. ON’BLE MR. ON’BLE MR. JUSTICE SUNI JUSTICE SUNI JUSTICE SUNI JUSTICE SUNI Mr. M.S. Kanda, Advocate, for the 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 29.03.2023 issued to the petitio ct, 1961 alongwith consequential ending application(s), if any, sha

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

AB AND HARYANA AB AND HARYANA AB AND HARYANA AB AND HARYANA H WP WP WP WP-6617 6617 6617 6617-2024 2024 2024 2024 (O&M) (O&M) (O&M) (O&M) 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 e 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. all also stand disposed of. (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 2026.09.19 11:39 I attest to the accuracy and integrity of this document

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