M/S JASDEEP KAUR CHADHA vs. DCIT CIRCLE 4, JALANDHAR

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CWP/11115/2024HC Punjab & HaryanaPHHC01062824202416 September 2026Bench: MR. JUSTICE SUNISH BINDLISH,MR. JUSTICE DEEPAK SIBAL1 pages
AI SummaryPartly Allowed

What did the High Court hold?

The Tribunal held that the petitioner would be entitled to the same relief as has been granted in the case of Jyoti Sareen vs. Union of India (CWP-15791-2024), which was decided on 10.09.2026. This decision was based on a consensus reached between the parties. Consequently, the impugned notice dated 18.03.2024 issued to the petitioner under Section 148 of the Income Tax Act, 1961, along with any consequential proceedings, were quashed. The ratio decidendi is that when parties agree to a settlement based on a prior favorable judgment for a similar issue, the court will uphold that consensus to dispose of the matter efficiently. The operative direction was to quash the notice and consequential proceedings.

What were the facts?

The petitioner, M/s Jasdeep, filed a writ petition before the High Court of Punjab and Haryana. The respondents were the DCIT Circle E 4, Jalandhar, and others. The petition challenged an order or action under Section 148 of the Income Tax Act, 1961, and consequential proceedings. The High Court noted that the parties agreed to the petitioner receiving the same relief as granted in a previous case, CWP-15791-2024 – Jyoti Sareen vs. Union of India, decided on 10.09.2026. This consensus was reached based on a notice dated 18.03.2024 issued to the petitioner. The judgment does not specify the assessment year(s) or the amount in dispute.

What were the issues?

1. Whether the petitioner is entitled to the same relief as granted in Jyoti Sareen vs. Union of India (CWP-15791-2024) concerning proceedings initiated under Section 148 of the Income Tax Act, 1961? (Mixed question of law and fact, concerning the application of a previous judgment and the validity of Section 148 proceedings). Assessee's contention: The petitioner argued, through their counsel, that they should be entitled to the same relief as granted in the aforementioned Jyoti Sareen case. This implies an argument that the facts or legal position warrant similar treatment. Revenue's contention: The revenue, represented by the Sr. Standing Counsel and junior counsel, agreed with the petitioner's submission, consenting to the petitioner being granted the same relief as in the Jyoti Sareen case. No specific authorities or precedents were named by either side in the judgment.

Which sections of the Income-tax Act were involved?

Section 148

AI-generated summary — verify with the full judgment below

214 214 214 214

IN T IN T IN T IN T M/S JASDEEP M/S JASDEEP M/S JASDEEP M/S JASDEEP DCIT CIRCLE DCIT CIRCLE DCIT CIRCLE DCIT CIRCLE

CORAM: CORAM: CORAM: CORAM: HO HO

HO HO

Present : M

(T 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

16.09 16.09 16.09 16.09.2026 .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

P P P P KAUR CHADHA KAUR CHADHA KAUR CHADHA KAUR CHADHA

VERSUS VERSUS VERSUS VERSUS E 4, JALANDHAR E 4, JALANDHAR E 4, JALANDHAR E 4, JALANDHAR

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 Kumar Mukhi, Advocate Through VC) Mr. Varun Issar, Sr. Standing Coun s. Pridhi Sandhu, Advocate and s. Nikita Garg, Jr. Standing Coun r the respondents-Income Tax D *** 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 18.03.2024 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-11115 11115 11115 11115-2024 2024 2024 2024 ate of Decision : ate of Decision : ate of Decision : ate of Decision : 16.09. 16.09. 16.09. 16.09.2026 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, for the petitioner. nsel with

nsel, epartment.

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 2026.09.19 12:08 I attest to the accuracy and integrity of this document

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