PREETI SETHI vs. INCOME TAX OFFICER AND ORS

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CWP/26025/2024HC Punjab & HaryanaPHHC01133257202411 September 2026Bench: MR. JUSTICE SUNISH BINDLISH,MR. JUSTICE DEEPAK SIBAL1 pages
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What did the High Court hold?

The High Court, upon agreement between the counsel for the petitioner and the respondents (revenue), allowed the petition. The Court quashed the impugned notice dated 27.03.2024 issued to the petitioner under Section 148 of the Income Tax Act, 1961, along with any consequential proceedings. The reasoning was based on the consensus that the petitioner was entitled to the same relief as had been granted in a prior judgment of the Court dated 10.09.2026 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, Preeti Sethi, filed a writ petition before the High Court of Punjab and Haryana at Chandigarh. The petition challenged a notice dated 27.03.2024 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 parties, through their respective counsel, agreed that the petitioner would 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 and others. The High Court was considering the present writ petition based on this consensus.

What were the issues?

1. Whether the notice dated 27.03.2024 issued to the petitioner under Section 148 of the Income Tax Act, 1961, and consequential proceedings are liable to be quashed? (Question of law and fact, concerning the validity of reassessment proceedings). Assessee's Contention: The petitioner sought the same relief as granted in Jyoti Sareen vs. Union of India and others (CWP-15791-2024), implying that the grounds for challenging the Section 148 notice in that case would apply here. Revenue's Contention: The revenue, through its counsel, agreed that the petitioner would be entitled to the same relief as granted in Jyoti Sareen's case. This indicates the revenue did not contest the quashing of the notice 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-26025-2024 (O&M) 208 IN THE HIGH COURT OF PUNJAB AND HARYANA AT CHANDIGARH CWP-26025-2024 (O&M) Date of decision : 11.09.2026 Preeti Sethi ...Petitioner Versus Income Tax Officer and others ...Respondents CORAM: HON’BLE MR. JUSTICE DEEPAK SIBAL HON’BLE MR. JUSTICE SUNISH BINDLISH Present: Ms. Ubhai Bharti Gupta, Advocate for the petitioner. (through V.C.). Ms. Gauri Neo Rampal, Senior Standing Counsel (through V.C.) 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 27.03.2024 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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