SHOBHNA BEDI vs. ADDITIONAL CIT, RANGE-4, LUDHIANA AND OTHERS

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CWP/18668/2021HC Punjab & HaryanaPHHC01084096202130 April 2026Bench: MR. JUSTICE DEEPAK SIBAL,MS. JUSTICE LAPITA BANERJI1 pages
AI SummaryRemanded

What did the High Court hold?

The High Court disposed of the petition based on the concession made by the revenue. The revenue conceded that the impugned notice dated March 31, 2021, dispatched to the petitioner on or after April 1, 2021, for the assessment year 2015-16, under Section 148 of the Income Tax Act, 1961, should be treated as a notice under Section 148A(b) of the Act, following the Supreme Court's ruling in Union of India vs. Ashish Agarwal. The Court directed the respondents-revenue to proceed from the stage of the notice under Section 148A(b) of the Act. The petitioner was granted liberty to raise all available pleas and defenses during the subsequent proceedings. No specific issue was left undecided, as the matter was resolved through concession and procedural direction.

What were the facts?

The petitioner, Shobhna Bedi, filed a writ petition before the High Court of Punjab & Haryana at Chandigarh challenging a notice dated March 31, 2021, issued under Section 148 of the Income Tax Act, 1961, for the assessment year 2015-16. The notice was dispatched on or after April 1, 2021. The revenue, represented by the Additional CIT, Ludhiana, and others, made a concession before the Court. The counsel for the revenue agreed that the impugned notice should be treated as a notice under Section 148A(b) of the Act, in light of the Supreme Court's decision in Union of India vs. Ashish Agarwal.

What were the issues?

1. Whether the notice dated March 31, 2021, issued under Section 148 of the Income Tax Act, 1961, for the assessment year 2015-16, dispatched on or after April 1, 2021, should be treated as a notice under Section 148A(b) of the Act, in light of the Supreme Court's decision in Union of India vs. Ashish Agarwal (2023) 1 SCC 617? Assessee's Contention: The petitioner's counsel was satisfied with the revenue's concession. Revenue's Contention: The revenue conceded that the impugned notice should be treated as a notice under Section 148A(b) of the Act, in terms of the law laid down by the Supreme Court in Union of India vs. Ashish Agarwal.

Which sections of the Income-tax Act were involved?

Section 148,Section 148A(b)

AI-generated summary — verify with the full judgment below

IN THE HIGH COURT OF PUNJAB & HARYANA AT CHANDIGARH

Sr. No. 279.6 CWP-18668-2021 Date of decision : 30.04.2026 Shobhna Bedi

.…. Petitioner Versus Additional CIT, Ludhiana and others

..... Respondents

CORAM : HON'BLE MR. JUSTICE DEEPAK SIBAL

HON'BLE MS. JUSTICE LAPITA BANERJI

Present : Mr. Vishal Gupta, Advocate, for the petitioner.

Mr. Ranvijay Singh, Sr. Standing Counsel,

Mr. Vidul Kapoor, Advocate, and

Ms. Nikita Garg, Advocate, for the Income Tax Department. * * * * * DEEPAK SIBAL, J. (Oral) 1.

At the outset, learned counsel for the revenue concedes that in terms of the law laid down by the Supreme Court in Union of India and others vs. Ashish Agarwal (2023) 1 SCC 617, the impugned notice dated 31.03.2021, dispatched to the petitioner on or after 01.04.2021, for the assessment year 2015-16, under Section 148 of the Income Tax Act, 1961 (for short-the Act) be treated as notice under Section 148A(b) of the Act. 2.

The above concession satisfies learned counsel for the petitioner. Accordingly, the present petition is disposed of with a direction to the respondent(s)- revenue to proceed from the stage of the afore notice, in terms of the procedure laid down under Section 148A(b) of the Act. 3.

Needless to add that in the course of the afore proceedings the petitioner shall be at liberty to raise all possible pleas/defences that may be available to her, in accordance with law.

[DEEPAK SIBAL]

JUDGE

30.04.2026

[LAPITA BANERJI] shamsher

JUDGE

Whether speaking/reasoned : Yes / No Whether reportable : Yes / No SHAMSHER SINGH 2026.05.05 12:54 I attest to the accuracy and integrity of this document Punjab and haryana high court, chandigarh

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