RAJNI DEVI vs. INCOME TAX OFFICER AND OTHERS

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CWP/19487/2025HC Punjab & HaryanaPHHC01107379202518 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 is entitled to the same relief as granted in the case of Jyoti Sareen vs. Union of India and others (CWP-15791-2024). Consequently, the impugned notice dated 25.03.2023 issued to the petitioner under Section 148 of the Income Tax Act, 1961, along with any consequential proceedings, was quashed. The reasoning was based on the agreement of the counsel for both the petitioner and the revenue. The ratio decidendi is that where parties agree to a specific outcome based on a prior judgment of the same court, the court will grant that relief. No issues were expressly left undecided.

What were the facts?

The petitioner, Rajni Devi, filed a writ petition before the High Court of Punjab and Haryana challenging a notice dated 25.03.2023 issued under Section 148 of the Income Tax Act, 1961, and any consequential proceedings. The respondents were the Income Tax Officer and others. Both the petitioner and the revenue, through 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, titled Jyoti Sareen vs. Union of India and others. The specific assessment year(s) and the amount in dispute were not recorded in this judgment.

What were the issues?

1. Whether the petitioner is entitled to the same relief as granted in the case of Jyoti Sareen vs. Union of India and others (CWP-15791-2024) dated 10.09.2026, concerning a notice issued under Section 148 of the Income Tax Act, 1961. Assessee's contention: The petitioner argued that she should be granted the same relief as was awarded in the aforementioned Jyoti Sareen case, based on the consensus reached with the revenue. No specific authorities or precedents were named by the petitioner's counsel in this judgment. Revenue's contention: The revenue, through its Sr. Standing Counsel, agreed with the petitioner's submission that the petitioner is entitled to the same relief as granted in the Jyoti Sareen case. No specific authorities or precedents were named by the revenue's counsel in this judgment.

Which sections of the Income-tax Act were involved?

Section 148

AI-generated summary — verify with the full judgment below

CWP-19487-2025 (O&M) 115 IN THE HIGH COURT OF PUNJAB AND HARYANA AT CHANDIGARH CWP-19487-2025 (O&M) Date of decision : 18.09.2026 Rajni Devi ...Petitioner Versus Income Tax Officer and others ...Respondents CORAM: HON’BLE MR. JUSTICE DEEPAK SIBAL HON’BLE MR. JUSTICE SUNISH BINDLISH Present: Mr. Rohit Kaura, Advocate for the petitioner. Mr. Ranvijay Singh, Sr. 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 25.03.2023 issued to the petitioner under Section 148 of the Income Tax Act, 1961 alongwith consequential proceedings, if any. (DEEPAK SIBAL) JUDGE (SUNISH BINDLISH) JUDGE 18.09.2026 Harish Kumar Whether speaking / reasoned: Yes No Whether Reportable : Yes No

-1- HARISH KUMAR 2026.09.22 14:02 I attest to the accuracy and integrity of this document

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