AMRIT OILS CHEMICALS vs. ASSISSTANT COMMISSIONER OF INCOME TAX

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CWP/11232/2024HC Punjab & HaryanaPHHC01063205202414 September 2026Bench: 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 the precedent set in the case of Jyoti Sareen vs. Union of India (CWP-15791-2024), allowed the petition. The Court quashed the impugned notice issued to the petitioner under Section 148 of the Income Tax Act, 1961, and any consequential assessment proceedings. The ratio decidendi is that where parties agree to a consent order based on a prior judgment, the court will extend the same relief to maintain consistency and fairness. The operative direction was the quashing of the reassessment proceedings. No issues were expressly left undecided.

What were the facts?

The petitioner, Amrit Oils and Chemicals, filed a writ petition before the High Court of Punjab and Haryana. The petition challenged an order or action by the Income Tax Department, specifically concerning proceedings initiated under Section 148 of the Income Tax Act, 1961. The assessment years are not explicitly stated. The procedural history indicates that the parties agreed to a consent order. The High Court referred to a previous judgment in CWP-15791-2024 – Jyoti Sareen vs. Union of India and others, dated 10.09.2026, and a notice dated 06.04.2023 issued to the petitioner. The dispute involves the validity of the reassessment proceedings.

What were the issues?

1. Whether the impugned notice/proceedings under Section 148 of the Income Tax Act, 1961, are valid and sustainable in law, considering the facts and circumstances of the case? (Question of law and fact) Assessee's Contention: The assessee sought relief based on a consent order granted in a similar case, Jyoti Sareen vs. Union of India. They agreed to the same relief as granted in that case, implying that the impugned proceedings should be quashed. Revenue's Contention: The revenue, represented by the Income Tax Department, agreed to the same relief as granted in the Jyoti Sareen case. This implies they consented to the quashing of the impugned proceedings, likely due to the precedent set in the earlier case or other concessions.

Which sections of the Income-tax Act were involved?

Section 148

AI-generated summary — verify with the full judgment below

255 255 255 255

IN T IN T IN T IN T

AMRIT OILS AMRIT OILS AMRIT OILS AMRIT OILS ASSISSTANT ASSISSTANT ASSISSTANT ASSISSTANT

CORAM: CORAM: CORAM: CORAM: HO HO

HO HO

Present : 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 0 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

AND AND AND AND CHEMICALS CHEMICALS CHEMICALS CHEMICALS

VERSUS VERSUS VERSUS VERSUS T COMMISSIONER OF INCO T COMMISSIONER OF INCO T COMMISSIONER OF INCO T COMMISSIONER OF INCO 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. S. K. Mukhi, Advocate, for the Mr. Ranvijay Singh, Sr. Standing C r. Vidul Kapoor, Jr. Standing Co 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 06.04.2023 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-11232 11232 11232 11232-2024 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 OME TAX OME TAX OME TAX OME TAX ...RESPONDENTS ...RESPONDENTS ...RESPONDENTS ...RESPONDENTS PAK SIBAL PAK SIBAL PAK SIBAL PAK SIBAL ISH BINDLISH ISH BINDLISH ISH BINDLISH ISH BINDLISH e petitioner. Counsel with unsel, 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 11:39 I attest to the accuracy and integrity of this document

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