SAMRAJ AND SONS vs. CENTRAL BOARD OF DIRECT TAXES AND ORS

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CWP/1429/2025HC Punjab & HaryanaPHHC01008407202502 September 2026Bench: MR. JUSTICE SUNISH BINDLISH,MR. JUSTICE DEEPAK SIBAL1 pages
AI SummaryWithdrawn

What did the High Court hold?

The High Court allowed the petitioner's request to withdraw the writ petition. The court granted liberty to the petitioner to file a fresh petition on the same cause of action. Crucially, the liberty also extended to challenging Section 147A of the Income-tax Act, 1961, in the new petition. The court's decision was based solely on the petitioner's request for withdrawal and the subsequent grant of liberty. No substantive issues regarding the merits of the case or the validity of Section 147A were adjudicated upon. The operative direction was the dismissal of the petition as withdrawn with the specified liberty.

What were the facts?

The petitioner, Samraj and Sons, filed a writ petition (CWP-1429-2025) before the High Court of Punjab & Haryana at Chandigarh. The respondents were the Central Board of Direct Taxes, New Delhi, and others. The petition was listed for decision on 02.09.2026. The petitioner's counsel appeared, as did the revenue's counsel. The core of the matter was a challenge to certain provisions of the Income-tax Act, 1961, specifically Section 147A, which the petitioner sought to include in a fresh petition.

What were the issues?

1. Whether the petitioner is entitled to withdraw the present writ petition with liberty to file a fresh one on the same cause of action and to challenge Section 147A of the Income-tax Act, 1961. The petitioner's contention was that they wished to withdraw the current petition to file a new one that would encompass a challenge to Section 147A of the Income-tax Act, 1961. No specific arguments were recorded for the revenue regarding this request.

Which sections of the Income-tax Act were involved?

Section 147A

AI-generated summary — verify with the full judgment below

IN THE HIGH COURT OF PUNJAB & HARYANA AT CHANDIGARH

Sr. No. 113

CWP-1429-2025 Date of decision : 02.09.2026

Samraj and Sons

.…. Petitioner Versus Central Board of Direct Taxes, New Delhi and others ..... Respondents

CORAM : HON'BLE MR. JUSTICE DEEPAK SIBAL

HON'BLE MR. JUSTICE SUNISH BINDLISH

Present : Mr. Divya Suri, Advocate, for the petitioner.

Mr. Saurabh Kapoor, Senior Standing Counsel

Mr. Rana Gurtej Singh, Junior Standing Counsel,

for the respondent(s)-revenue.

* * * * * DEEPAK SIBAL, J. (Oral) 1. Learned counsel for the petitioner seeks to withdraw this petition with liberty to the petitioner to file a fresh one on the same cause of action as also to challenge therein Section 147A of the Income-tax Act, 1961. 2. Dismissed as withdrawn with liberty as prayed for.

[DEEPAK SIBAL]

JUDGE

02.09.2026

[SUNISH BINDLISH] shamsher

JUDGE

Whether speaking/reasoned : Yes / No Whether reportable : Yes / No SHAMSHER SINGH 2026.09.03 14:59 I attest to the accuracy and integrity of this document Punjab and haryana high court, chandigarh

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