SARAL HOME EASY LIVING PRIVATE LIMITED THROUGH ITS DIRECTOR SH AMIT AGGARWAL vs. INCOME TAX OFFICER WARD 1 AMBALA AND ANOTHERS
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?
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
More judgments on Section 148
- ACIT Central Bilaspur, Bilaspur vs Arun Kumar Agrawal, SaktiITSSA 26/RPR/2025[2018-19]Status: Disposed21 Oct 2026AY 2018-19
- Vinod Agrawal, Kawardha vs Assisstant Commissioner of Income Tax…ITA 666/RPR/2026[2019-20]Status: Heard21 Oct 2026AY 2019-20
- 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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