SARAL HOME EASY LIVING PRIVATE LIMITED THROUGH ITS DIRECTOR SH AMIT AGGARWAL vs. INCOME TAX OFFICER WARD 1 AMBALA AND ANOTHERS

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CWP/20354/2025HC Punjab & HaryanaPHHC01111707202518 September 2026Bench: MR. JUSTICE SUNISH BINDLISH,MR. JUSTICE DEEPAK SIBAL1 pages
AI SummaryAllowed

What did the High Court hold?

The High Court held that the petitioner would be entitled to the same relief as granted in the judgment dated 10.09.2026 in CWP-15791-2024 (Jyoti Sareen vs. Union of India & others). Based on this consensus between the parties, the Court allowed the petition. The impugned notice dated 22.06.2025, issued to the petitioner under Section 148 of the Income Tax Act, 1961, was quashed. Any consequential proceedings arising from this notice were also quashed. The ratio decidendi is that where parties agree to extend the benefit of a prior judgment to a new assessee, and the facts are analogous, the Court will uphold this agreement and grant the same relief. The operative direction was the quashing of the notice and consequential proceedings.

What were the facts?

The petitioner, Saral Home Easy Living Pvt. Ltd., challenged a notice dated 22.06.2025 issued under Section 148 of the Income Tax Act, 1961, along with any consequential proceedings. The case was heard by the High Court of Punjab and Haryana. The revenue was represented by the Income Tax Officer and another. Both parties 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 & others.

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 & others (CWP-15791-2024) decided on 10.09.2026, concerning a notice issued under Section 148 of the Income Tax Act, 1961. Assessee's Contention: The petitioner argued, and the revenue agreed, that the petitioner should be granted the same relief as awarded in the aforementioned Jyoti Sareen case. No specific arguments or reliance on authorities were detailed for the petitioner beyond this consensus. Revenue's Contention: The revenue, through its counsel, agreed with the petitioner's submission that the relief granted in Jyoti Sareen's case should be extended to the petitioner. No specific arguments or reliance on authorities were detailed for the revenue beyond this consensus.

Which sections of the Income-tax Act were involved?

Section 148

AI-generated summary — verify with the full judgment below

121 IN THE HIGH COURT OF PUNJAB AND HARYANA AT CHANDIGARH CWP-20354-2025 Date of decision: 18.09.2026 Saral Home Easy Living Pvt. Ltd.

… Petitioner Versus Income Tax Officer & another … Respondents

CORAM: HON’BLE MR. JUSTICE DEEPAK SIBAL HON’BLE MR. JUSTICE SUNISH BINDLISH Present: Ms. Divya Arora & Mr. Amit Kaushik, Advocates for the petitioner. Mr. Saurabh Kapoor, Sr. Standing Counsel with Mr. Rana Gurtej Singh, Jr. Standing Counsel, and Ms. Muskan Gupta, Advocate

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 & 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 22.06.2025 issued to the petitioner under Section 148 of the Income Tax Act, 1961 alongwith consequential proceedings, if any.

(DEEPAK SIBAL) JUDGE

(SUNISH BINDLISH) JUDGE September 18, 2026 rps Whether speaking/reasoned

Yes/No Whether reportable

Yes/No RATTAN PAL SINGH 2026.09.21 12:26 I attest to the accuracy and integrity of this document

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