MUKTSAR COTTON PRIVATE LIMITED vs. INCOME TAX OFFICER AND OTHERS

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CWP/22392/2024HC Punjab & HaryanaPHHC01116687202411 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 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 and others). Based on this consensus between the parties, the petition was allowed. The Court quashed the impugned notice dated 19.04.2024, issued to the petitioner under Section 148 of the Income Tax Act, 1961, along with any consequential proceedings. The ratio decidendi is that if a party is similarly situated to a party in a prior judgment of the same court, and the revenue agrees to the same relief, then the prior judgment's outcome will be applied. No issues were expressly left undecided.

What were the facts?

The petitioner, Muktsar Cotton Pvt. Ltd., filed a writ petition before the High Court of Punjab and Haryana at Chandigarh. The petition challenged a notice dated April 19, 2024, issued to the petitioner under Section 148 of the Income Tax Act, 1961, and any consequential proceedings. The assessment year(s) are not specified in the judgment. The respondents are the Income Tax Officer and others. The parties reached a consensus that the petitioner should receive the same relief as granted in a previous judgment of the same Court dated September 10, 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 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 they should be granted the same relief as was granted by this Court in the case of Jyoti Sareen vs. Union of India and others, dated 10.09.2026. This implies the petitioner sought the quashing of the impugned notice and consequential proceedings. Revenue's contention: The revenue, through its learned counsel, agreed with the petitioner's submission that the petitioner would be entitled to the same relief as granted in the aforementioned Jyoti Sareen case. This indicates the revenue did not oppose the petitioner's claim based on the precedent.

Which sections of the Income-tax Act were involved?

Section 148

AI-generated summary — verify with the full judgment below

CWP-22392-2024 (O&M) 205 IN THE HIGH COURT OF PUNJAB AND HARYANA AT CHANDIGARH CWP-22392-2024 (O&M) Date of decision : 11.09.2026 Muktsar Cotton Pvt. Ltd. ...Petitioner Versus Income Tax Officer and others ...Respondents CORAM: HON’BLE MR. JUSTICE DEEPAK SIBAL HON’BLE MR. JUSTICE SUNISH BINDLISH Present: Ms. Aakanksha, Advocate and Ms. Shweta, Advocate for Mr. Nikhil Goyal, Advocate for the petitioner. Ms. Urvashi Dhugga, Sr. Standing Counsel Mr. Vaibhav Gupta, Jr. Standing Counsel and Ms. Kavita, Advocate for the respondent(s). 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 19.04.2024 issued to the petitioner under Section 148 of the Income Tax Act, 1961 alongwith consequential proceedings, if any. (DEEPAK SIBAL) JUDGE (SUNISH BINDLISH) JUDGE 11.09.2026 Harish Kumar Whether speaking / reasoned: Yes No Whether Reportable : Yes No

-1- HARISH KUMAR 2026.09.14 18:06 I attest to the accuracy and integrity of this document

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