RADHEY SHYAM GOYAL PROP M/S SUNDRAM STEEL vs. INCOME TAX OFFICER

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CWP/21025/2025HC Punjab & HaryanaPHHC01114661202514 September 2026Bench: MR. JUSTICE SUNISH BINDLISH,MR. JUSTICE DEEPAK SIBAL1 pages
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What did the High Court hold?

The High Court of Punjab and Haryana at Chandigarh, in light of the consensus reached between the parties, allowed the petition. The Court quashed the impugned notice dated 21.05.2025, issued to the petitioner under Section 148 of the Income Tax Act, 1961, along with any consequential proceedings. The reasoning was based on the agreement of both the petitioner and the revenue that the petitioner should receive the same relief as had been granted in a prior judgment of the same Court in CWP-15791-2024 (Jyoti Sareen vs. Union of India and others). The ratio decidendi is that where parties agree to follow a precedent set by the same court in a similar matter, the court will grant the same relief. No issues were left undecided.

What were the facts?

The petitioner, Radhey Shyam Goyal, proprietor of M/s Sundram Steel, filed a writ petition before the High Court of Punjab and Haryana at Chandigarh. The petition challenged a notice dated 21.05.2025 issued to the petitioner under Section 148 of the Income Tax Act, 1961, and any consequential proceedings. The respondents were the Income Tax Officer and others. The parties, through their learned 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 (Jyoti Sareen vs. Union of India and 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 and others, decided on 10.09.2026 by this Court? Assessee's contention: The petitioner, through their counsel, agreed that they would be entitled to the same relief as granted in the aforementioned Jyoti Sareen case. No specific arguments were detailed in the judgment, but the consensus indicates acceptance of the precedent. Revenue's contention: The revenue, through their learned Senior Standing Counsel, also agreed to the petitioner receiving the same relief as granted in the Jyoti Sareen case. No specific arguments were detailed in the judgment, but the consensus indicates acceptance of the precedent.

Which sections of the Income-tax Act were involved?

Section 148

AI-generated summary — verify with the full judgment below

CWP-21025-2025 (O&M) 173 IN THE HIGH COURT OF PUNJAB AND HARYANA AT CHANDIGARH CWP-21025-2025 (O&M) Date of decision : 14.09.2026 Radhey Shyam Goyal prop. M/s Sundram Steel ...Petitioner Versus Income Tax Officer and others ...Respondents CORAM: HON’BLE MR. JUSTICE DEEPAK SIBAL HON’BLE MR. JUSTICE SUNISH BINDLISH Present: Mr.Salil Dev Singh Bali, Sr. Advocate with Mr. Sunil K. Mukhi, Advocate for the petitioner. Mr.Saurabh Kapoor, Senior Standing Counsel with Mr. Rana Gurtej Singh, 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 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 21.05.2025 issued to the petitioner under Section 148 of the Income Tax Act, 1961 alongwith consequential proceedings, if any. (DEEPAK SIBAL) JUDGE (SUNISH BINDLISH) JUDGE 14.09.2026 Harish Kumar Whether speaking / reasoned: Yes No Whether Reportable : Yes No

-1- HARISH KUMAR 2026.09.17 09:00 I attest to the accuracy and integrity of this document

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