PARAS HEALTHCARE LTD vs. ACIT

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CWP/3270/2025HC Punjab & HaryanaPHHC01018524202511 September 2026Bench: MR. JUSTICE SUNISH BINDLISH,MR. JUSTICE DEEPAK SIBAL1 pages
AI SummaryAllowed

What did the High Court hold?

The High Court, in light of the consensus between the parties and following the precedent set in Jyoti Sareen's case (CWP-15791-2024) decided on 10.09.2026, allowed the petition. The Court quashed the impugned notice issued to the petitioner under Section 148 of the Income Tax Act, 1961, and also set aside any consequential proceedings that may have arisen from it. The reasoning was based on the agreement of the parties to grant the petitioner the same relief as was granted in the cited case. The ratio decidendi is that where parties consent to a particular outcome based on a prior judicial precedent, the court can grant that relief. No issue was expressly left undecided.

What were the facts?

The petitioner, Paras Healthcare Ltd., filed a writ petition before the High Court of Punjab and Haryana. The petition challenged an action by the Assessing Officer (ACIT, Central Circle, Faridabad) under Section 148 of the Income Tax Act, 1961, which involves reopening of assessment. The specific action under challenge was a notice dated 24.03.2024. The procedural history indicates that the petitioner sought the same relief as granted in a previous case, CWP-15791-2024 – Jyoti Sareen vs. Union of India and others, decided on 10.09.2026. The parties agreed to a consent order.

What were the issues?

1. Whether the notice issued by the Assessing Officer under Section 148 of the Income Tax Act, 1961, is valid and justified? (Question of law and mixed fact and law) Assessee's Contention: The assessee argued that the impugned notice should be quashed and consequential proceedings dropped, seeking parity with the relief granted in Jyoti Sareen's case. The assessee relied on the judgment in Jyoti Sareen vs. Union of India and others (CWP-15791-2024) decided on 10.09.2026. Revenue's Contention: The revenue, through its counsel, agreed to the same relief as granted in Jyoti Sareen's case. No specific arguments were recorded for the revenue beyond this consent.

Which sections of the Income-tax Act were involved?

Section 148

AI-generated summary — verify with the full judgment below

112 112 112 112

IN T IN T IN T IN T

PARAS HEAL PARAS HEAL PARAS HEAL PARAS HEAL ACIT ACIT ACIT ACIT, CENTR , CENTR , CENTR , CENTR

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 2 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 AT AT AT CHANDIGARH CHANDIGARH CHANDIGARH CHANDIGARH

CW CW CW CW Da Da Da Da

LTHCARE LTD LTHCARE LTD LTHCARE LTD LTHCARE LTD

VERSUS VERSUS VERSUS VERSUS RAL CIRCLE, FARIDABAD RAL CIRCLE, FARIDABAD RAL CIRCLE, FARIDABAD RAL CIRCLE, FARIDABAD-

ON'BLE MR. JUSTICE ON'BLE MR. JUSTICE ON'BLE MR. JUSTICE ON'BLE MR. JUSTICE DEEP DEEP DEEP DEEP ON’BLE MR. JUSTICE ON’BLE MR. JUSTICE ON’BLE MR. JUSTICE ON’BLE MR. JUSTICE SUNI SUNI SUNI SUNI Mr. Salil Aggarwal, Sr. Advocate ( r. Ashim Aggarwal, Advocate, fo 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 24.03.2024 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-3270 3270 3270 3270-2025 2025 2025 2025 ate of Decision : ate of Decision : ate of Decision : ate of Decision : 11.09. 11.09. 11.09. 11.09.2026 2026 2026 2026

...PETITIONER ...PETITIONER ...PETITIONER ...PETITIONER 2, FARIDABAD 2, FARIDABAD 2, FARIDABAD 2, FARIDABAD

...RESPONDENTS ...RESPONDENTS ...RESPONDENTS ...RESPONDENTS PAK SIBAL PAK SIBAL PAK SIBAL PAK SIBAL ISH BINDLISH ISH BINDLISH ISH BINDLISH ISH BINDLISH (Through VC) with or 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 2026.09.15 16:46 I attest to the accuracy and integrity of this document

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