SAMANYU ENTERPRISES vs. INCOME TAX OFFICER AND OTHERS
What did the High Court hold?
The High Court of Punjab and Haryana at Chandigarh, based on the consensus reached by the learned counsel for both the petitioner and the respondents, allowed the petition. The court directed that the petitioner would be entitled to the same relief as had been granted in the judgment dated 10.09.2026 in CWP-15791-2024, Jyoti Sareen vs. Union of India and others. Consequently, the impugned notice dated 30.06.2025, issued to the petitioner under Section 148 of the Income Tax Act, 1961, was quashed, along with any consequential proceedings. The reasoning is based entirely on the agreement of the parties to follow the precedent set in the Jyoti Sareen case. 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, Samanyu Enterprises, filed a writ petition before the High Court of Punjab and Haryana at Chandigarh. The petition challenged a notice dated 30.06.2025 issued under Section 148 of the Income Tax Act, 1961, and any consequential proceedings. The respondents were the Income Tax Officer, Ward 1(1), and others. The parties, through their respective counsel, agreed that the petitioner should receive the same relief as granted in a previous judgment by the same court dated 10.09.2026 in CWP-15791-2024, titled Jyoti Sareen vs. Union of India and others. The assessment year(s) and the specific amount in dispute are not recorded in the judgment.
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) dated 10.09.2026, concerning a notice 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 Jyoti Sareen case. No specific arguments were detailed, but the consensus implies reliance on the principles or facts established in the Jyoti Sareen judgment. Revenue's Contention: The revenue, through its Sr. Standing Counsel, agreed to the consensus that the petitioner should receive the same relief as granted in the Jyoti Sareen case. No specific arguments were detailed, but their agreement suggests acceptance of the precedent set in the earlier case.
Which sections of the Income-tax Act were involved?
AI-generated summary — verify with the full judgment below
CWP-19715-2025 (O&M) 116 IN THE HIGH COURT OF PUNJAB AND HARYANA AT CHANDIGARH CWP-19715-2025 (O&M) Date of decision : 18.09.2026 Samanyu Enterprises ...Petitioner Versus Income Tax Officer, Ward 1(1) and others ...Respondents CORAM: HON’BLE MR. JUSTICE DEEPAK SIBAL HON’BLE MR. JUSTICE SUNISH BINDLISH Present: Mr. Rajiv Sharma, Advocate and Mr. J.S. Bhasin, 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 30.06.2025 issued to the petitioner under Section 148 of the Income Tax Act, 1961 alongwith consequential proceedings, if any. (DEEPAK SIBAL) JUDGE (SUNISH BINDLISH) JUDGE 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
More judgments on Section 148
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- Sar Business Tradelink Private Limited… vs Income Tax Officer, Ward - 1(2), RaipurITA 599/RPR/2026[2014-15]Status: Heard21 Oct 2026AY 2014-15
- Neo Incorporation, Rajkot vs DCIT Circle- 1(2), RajkotITA 471/RJT/2026[2012-2013]Status: Disposed21 Oct 2026AY 2012-2013
- Adj Agri International LLP, Rajkot vs The Income Tax Officer, Ward-1(1)(1), RajkotITA 1198/RJT/2026[2018-19]Status: Disposed21 Oct 2026AY 2018-19
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