FLINT POWER TOOLS PRIVATE LIMITED vs. ASSISTANT COMMISSIONER OF INCOME TAX AND OTHERS

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CWP/11683/2025HC Punjab & HaryanaPHHC01064609202516 September 2026Bench: MR. JUSTICE SUNISH BINDLISH,MR. JUSTICE DEEPAK SIBAL1 pages
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What did the High Court hold?

The High Court held that, in light of the consensus between the parties, the petitioner was 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). Consequently, the petition was allowed. The impugned notice dated 30.03.2025 issued to the petitioner under Section 148 of the Income Tax Act, 1961, along with any consequential proceedings, was quashed. The ratio decidendi is that where parties agree to a specific outcome based on a prior binding precedent, the court will uphold that agreement and apply the precedent accordingly. No issues were left undecided.

What were the facts?

The petitioner, Flint Power Tools Pvt. Ltd., filed a writ petition (CWP-11683-2025) before the High Court of Punjab and Haryana at Chandigarh. The petition challenged a notice dated 30.03.2025 issued under Section 148 of the Income Tax Act, 1961, and any consequential proceedings. The respondents were the Assistant Commissioner of Income Tax, Central Circle 1, Faridabad, and others. Both the petitioner and the revenue, represented by their respective counsel, agreed that the petitioner should receive 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).

What were the issues?

1. Whether the petitioner is entitled to the same relief as granted in Jyoti Sareen vs. Union of India and others (CWP-15791-2024), concerning the validity of the notice issued under Section 148 of the Income Tax Act, 1961. Assessee's contention: The petitioner argued that they should be granted the same relief as in the cited case, implying that the notice under Section 148 was liable to be quashed. No specific arguments were detailed in the judgment, but the consensus suggests the petitioner relied on the precedent. Revenue's contention: The revenue, through its counsel, agreed to the consensus that the petitioner should receive the same relief as in Jyoti Sareen's case. This indicates the revenue did not contest the application of the previous judgment to the present case.

Which sections of the Income-tax Act were involved?

Section 148

AI-generated summary — verify with the full judgment below

CWP-11683-2025 (O&M) 111 IN THE HIGH COURT OF PUNJAB AND HARYANA AT CHANDIGARH CWP-11683-2025 (O&M) Date of decision : 16.09.2026 Flint Power Tools Pvt. Ltd. ...Petitioner Versus Assistant Commissioner of Income Tax, Central Circle 1, Faridabad and others ...Respondents CORAM: HON’BLE MR. JUSTICE DEEPAK SIBAL HON’BLE MR. JUSTICE SUNISH BINDLISH Present: Mr. Nikhil Goyal, Advocate and Ms. Ruby, Advocate for the petitioner. Mr.Ranvijay Singh, Sr. Standing Counsel with Mr. Vidul Kapoor, Jr. Standing Counsel for the respondent(s)-revenue. DEEPAK SIBAL, J.(Oral) 1. Learned counsel for the parties agree that the petitioner would also be entitled to the same relief as has been granted through a judgment of this Court dated 10.09.2026 passed in CWP-15791-2024- Jyoti Sareen vs. Union of India and others. 2. In the light of the above consensus, the petition is allowed in terms of Jyoti Sareen’s case (supra), resulting in quashing of the impugned notice dated 30.03.2025 issued to the petitioner under Section 148 of the Income Tax Act, 1961 alongwith consequential proceedings, if any. (DEEPAK SIBAL) JUDGE (SUNISH BINDLISH) JUDGE 16.09.2026 Harish Kumar Whether speaking / reasoned: Yes No Whether Reportable : Yes No

-1- HARISH KUMAR 2026.09.19 08:48 I attest to the accuracy and integrity of this document

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