JATINDER SINGH DADRA AY 2017 TO 18 vs. THE JOINT COMMISSIONER OF INCOME TAX (OSD), CENTRAL CIRCLE 1 AND OTHERS

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CWP/25813/2025HC Punjab & HaryanaPHHC01139628202511 September 2026Bench: MR. JUSTICE SUNISH BINDLISH,MR. JUSTICE DEEPAK SIBAL1 pages
AI SummaryPartly Allowed

What did the High Court hold?

The High Court of Punjab and Haryana held that, in light of the consensus reached between the parties, the petitioner would be entitled to the same relief as granted in the judgment dated 10.09.2026 in CWP-15791-2024 (Jyoti Sareen vs. Union of India and others). The court allowed the petition in terms of this consensus. The reasoning was based on the agreement of counsel, leading to the quashing of the impugned notice dated 17.03.2025 issued to the petitioner under Section 148 of the Income Tax Act, 1961, and any consequential proceedings. The ratio decidendi is that where parties agree to a specific outcome based on a prior binding precedent, the court should honor that consensus to avoid unnecessary litigation and ensure consistency. No issue was expressly left undecided.

What were the facts?

The petitioner, Jatinder Singh Dadra, filed a writ petition challenging a notice issued under Section 148 of the Income Tax Act, 1961. The respondents are the Joint Commissioner of Income Tax and others. The High Court of Punjab and Haryana, in its order dated 11.09.2026, noted that the learned counsel for the parties had agreed that the petitioner would be entitled to the same relief as granted in a previous judgment of the same court dated 10.09.2026 in CWP-15791-2024 (Jyoti Sareen vs. Union of India and others). Consequently, the petition was allowed in terms of the consensus reached, resulting in the quashing of the impugned notice dated 17.03.2025 and any consequential proceedings.

What were the issues?

1. Whether the impugned notice issued under Section 148 of the Income Tax Act, 1961, is liable to be quashed? (Question of law and fact, concerning Section 148 of the Income Tax Act, 1961). Assessee's contention: The assessee argued that they should be granted the same relief as was provided in the case of Jyoti Sareen vs. Union of India and others, citing the High Court's judgment dated 10.09.2026 in CWP-15791-2024. This implies an agreement that the notice was flawed and should be quashed. Revenue's contention: The revenue, through its learned counsel, agreed with the assessee's submission that the petitioner should be entitled to the same relief as granted in the aforementioned Jyoti Sareen case. This indicates a consensus to quash the notice.

Which sections of the Income-tax Act were involved?

Section 148

AI-generated summary — verify with the full judgment below

148 148 148 148

IN T IN T IN T IN T JATINDER SI JATINDER SI JATINDER SI JATINDER SI THE JOINT C THE JOINT C THE JOINT C THE JOINT C CIRCLE 1 AN CIRCLE 1 AN CIRCLE 1 AN CIRCLE 1 AN

CORAM: CORAM: CORAM: CORAM: HO HO

HO HO

Present : M M 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

11.09 11.09 11.09 11.09.2026 .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

INGH DADRA INGH DADRA INGH DADRA INGH DADRA

VERSUS VERSUS VERSUS VERSUS COMMISSIONER OF INCOM COMMISSIONER OF INCOM COMMISSIONER OF INCOM COMMISSIONER OF INCOM ND OTHERS ND OTHERS ND OTHERS ND OTHERS

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. Rochak Singla, Advocate, for Ms. Urvashi Dhugga, Sr. Standing r. Vaibhav Gupta, Jr. Standing C s. Kavita, Advocate and s. Arushi Bansal, Advocate 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 17.03.2025 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-25813 25813 25813 25813-2025 2025 2025 2025 ate of ate of ate of ate of Decision : Decision : Decision : Decision : 11.09. 11.09. 11.09. 11.09.2026 2026 2026 2026

...PETITIONER ...PETITIONER ...PETITIONER ...PETITIONER ME TAX (OSD), CENTRAL ME TAX (OSD), CENTRAL ME TAX (OSD), CENTRAL ME TAX (OSD), CENTRAL

...RESPONDENTS ...RESPONDENTS ...RESPONDENTS ...RESPONDENTS PAK SIBAL PAK SIBAL PAK SIBAL PAK SIBAL ISH BINDLISH ISH BINDLISH ISH BINDLISH ISH BINDLISH the petitioner. g Counsel with 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. (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 2026.09.14 19:32 I attest to the accuracy and integrity of this document

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