SUSHIL SPUNTEX PRIVATE LIMITED THROUGH ITS DIRECTOR SH SUSHIL GARG vs. DEPUTY COMMISSIONER OF INCOME TAX CENTRAL CIRCLE KARNAL AND ANR
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 impugned notice dated 27.06.2025, issued to the petitioner under Section 148 of the Income Tax Act, 1961, was quashed, along with any consequential proceedings. The ratio decidendi is that where parties agree that a case should follow a prior precedent of the same court, the court will grant the same relief. No issues were expressly left undecided.
What were the facts?
The petitioner, Sushil Spuntex Private Limited, filed a writ petition before the High Court of Punjab and Haryana at Chandigarh. The petition challenged a notice dated 27.06.2025 issued under Section 148 of the Income Tax Act, 1961, and any consequential proceedings. The respondents were the Deputy Commissioner of Income Tax Circle, Karnal, and another revenue authority. 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 (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 (CWP-15791-2024) decided on 10.09.2026? (Question of law and fact, turning on the application of precedent). Assessee's Contention: The petitioner argued that they should be granted the same relief as was granted in the aforementioned Jyoti Sareen case. No specific authorities or precedents were named by the petitioner in the judgment, beyond referencing the Jyoti Sareen case. Revenue's Contention: The revenue, through its counsel, agreed with the petitioner's submission that the petitioner should be entitled to the same relief as granted in the Jyoti Sareen case. No specific authorities or precedents were named by the revenue in the judgment.
Which sections of the Income-tax Act were involved?
AI-generated summary — verify with the full judgment below
CWP-25872-2025 (O&M) 176 IN THE HIGH COURT OF PUNJAB AND HARYANA AT CHANDIGARH CWP-25872-2025 (O&M) Date of decision : 14.09.2026 Sushil Spuntex Private Limited ...Petitioner Versus Deputy Commissioner of Income Tax Circle, Karnal and another ...Respondents CORAM: HON’BLE MR. JUSTICE DEEPAK SIBAL HON’BLE MR. JUSTICE SUNISH BINDLISH Present: Mr.Amit Kaushik, Advocate for the petitioner. (through V.C.). Ms.Urvashi Dhugga, Sr. Standing Counsel and Ms. Kavita, 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 27.06.2025 issued to the petitioner under Section 148 of the Income Tax Act, 1961 alongwith consequential proceedings, if any. (DEEPAK SIBAL) JUDGE (SUNISH BINDLISH) JUDGE 14.09.2026 Harish Kumar Whether speaking / reasoned: Yes No Whether Reportable : Yes No
-1- HARISH KUMAR 2026.09.17 19:53 I attest to the accuracy and integrity of this document
More judgments on Section 148
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- 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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