NEETA GULATI vs. INCOME TAX OFFICER WARD 1

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CWP/14224/2024HC Punjab & HaryanaPHHC01077180202414 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 consensus between the parties and following its previous decision in Jyoti Sareen's case (supra), allowed the petition. The Court quashed the impugned notice dated 25.04.2024 issued to the petitioner under Section 148 of the Income Tax Act, 1961, and also quashed any consequential proceedings. The reasoning appears to be based on the acceptance of the petitioner's plea for similar relief as granted in the cited precedent, suggesting that the reassessment proceedings initiated by the notice were found to be without merit or improperly initiated, as per the understanding derived from the Jyoti Sareen judgment. No specific issue was left undecided.

What were the facts?

The case involves a writ petition filed by Neeta Gula (the petitioner) against the Income Tax Officer, Ward 1, Karnal (the respondent). The petitioner sought relief similar to that granted in CWP-15791-2024 – Jyoti Sareen vs. Union of India. The core of the dispute revolves around a notice dated 25.04.2024 issued to the petitioner under Section 148 of the Income Tax Act, 1961, initiating reassessment proceedings, and any consequential actions. The High Court of Punjab and Haryana was seized of this matter. The parties appeared through their respective counsel.

What were the issues?

1. Whether the impugned notice dated 25.04.2024 issued under Section 148 of the Income Tax Act, 1961, and consequential proceedings are liable to be quashed? (Mixed question of law and fact, concerning the validity of reassessment proceedings). Assessee's Contention: The petitioner sought parity with the relief granted in Jyoti Sareen's case (supra), implying that the notice and proceedings were flawed and should be set aside. Revenue's Contention: The revenue, through its Sr. Standing Counsel, agreed to the same relief as granted in Jyoti Sareen's case, indicating a consensus and acceptance of the petitioner's prayer without explicitly arguing against it.

Which sections of the Income-tax Act were involved?

Section 148

AI-generated summary — verify with the full judgment below

258 258 258 258

IN T IN T IN T IN T

NEETA GULA NEETA GULA NEETA GULA NEETA GULA INCOME TAX INCOME TAX INCOME TAX INCOME TAX

CORAM: CORAM: CORAM: CORAM: HO HO

HO HO

Present : M M fo (T **

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

14.

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

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

CW CW CW CW Da Da Da Da

ATI ATI ATI ATI

VERSUS VERSUS VERSUS VERSUS X OFFICER WARD 1 X OFFICER WARD 1 X OFFICER WARD 1 X OFFICER WARD 1 KARNA KARNA KARNA KARNA 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. Sunil K. Mukhi, Advocate, for Ms. Gauri Neo Rampal, Sr. Standi r the respondents-Income Tax D Through Video Conferencing) *** 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 25.04.2024 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-14224 14224 14224 14224-2024 2024 2024 2024 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 AL AL AL AL ...RESPONDENTS ...RESPONDENTS ...RESPONDENTS ...RESPONDENTS PAK SIBAL PAK SIBAL PAK SIBAL PAK SIBAL ISH ISH ISH ISH BINDLISH BINDLISH BINDLISH BINDLISH r the petitioner. ing Counsel Department. 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 15:26 I attest to the accuracy and integrity of this document

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