MIDLAND MICROFIN LIMITED vs. ASSISTANT COMMISSIONER OF INCOME TAX AND OTHERS

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CWP/11949/2024HC Punjab & HaryanaPHHC01067819202410 September 2026Bench: MR. JUSTICE SUNISH BINDLISH,MR. JUSTICE DEEPAK SIBAL1 pages
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What did the High Court hold?

The High Court, based on the consensus between the learned counsel for the petitioner and the respondents, allowed the petition. The Court held that the petitioner is entitled to the same relief as was granted in the judgment dated 10.09.2026 passed in CWP-15791-2024 (Jyoti Sareen vs. Union of India and others). Consequently, the impugned notice dated 08.04.2024 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 precedent being applied, the court will follow that precedent to grant similar relief. No issues were left undecided.

What were the facts?

The petitioner, Midland Microfin Limited, filed a writ petition before the High Court of Punjab & Haryana at Chandigarh challenging a notice dated 08.04.2024 issued under Section 148 of the Income Tax Act, 1961. The respondents are the Assistant Commissioner of Income Tax, Jalandhar, and others. The parties agreed that the petitioner should receive the same relief as granted in a previous judgment by the same Court in CWP-15791-2024, titled Jyoti Sareen vs. Union of India and others. The assessment year(s) are not specified in the judgment. The procedural history is limited to the filing of the writ petition and the subsequent agreement between the parties.

What were the issues?

1. Whether the petitioner is entitled to the same relief as granted in CWP-15791-2024 (Jyoti Sareen vs. Union of India and others) concerning the impugned notice dated 08.04.2024 issued under Section 148 of the Income Tax Act, 1961. Assessee's Contention: The petitioner, through its counsel, agreed that it would be entitled to the same relief as granted in the aforementioned judgment of this Court in Jyoti Sareen's case. Revenue's Contention: The revenue, through its counsel, also agreed to the petitioner receiving the same relief as granted in Jyoti Sareen's case. No specific arguments or reliance on authorities were recorded for either side beyond this consensus.

Which sections of the Income-tax Act were involved?

Section 148

AI-generated summary — verify with the full judgment below

IN THE HIGH COURT OF PUNJAB & HARYANA AT CHANDIGARH CWP-11949-2024 (O&M) Date of decision: 10.09.2026 MIDLAND MICROFIN LIMITED ..... Petitioner Versus ASSISTANT COMMISSIONER OF INCOME TAX, JALANDHAR AND OTHERS ..... Respondent(s) CORAM : HON'BLE MR. JUSTICE DEEPAK SIBAL

HON'BLE MR. JUSTICE SUNISH BINDLISH Present : Mr. Abhinav Narang, Advocate, for the petitioner. Mr. Ranvijay Singh, Sr. Standing Counsel with Mr. Vidul Kapoor, Jr. Standing Counsel for the respondents. * * * DEEPAK SIBAL, J. 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 08.04.2024 issued to the petitioner under Section 148 of the Income Tax Act, 1961, alongwith consequential proceedings, if any. (DEEPAK SIBAL) JUDGE 10.09.2026 (SUNISH BINDLISH) Jyoti 1

JUDGE Whether speaking/reasoned : Yes / No Whether reportable : Yes / No JYOTI SHARMA 2026.09.18 17:22 I attest to the accuracy and authenticity of this document

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