HARBHAJAN SINGH vs. INCOME TAX OFFICER
What did the High Court hold?
The High Court, based on the consensus between the learned counsel for the parties, allowed the petition. The 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. Consequently, the impugned notice dated 10.04.2024 issued to the petitioner under Section 148 of the Income Tax Act, 1961, along with any consequential proceedings, was quashed. The ratio decidendi is that if a similar issue has been decided in favour of an assessee in a prior judgment, and the revenue agrees to the same relief, the subsequent petition will be allowed on the same terms. No issue was expressly left undecided.
What were the facts?
The petitioner, Harbhajan Singh, filed a writ petition (CWP-28427-2025) before the High Court of Punjab and Haryana at Chandigarh. The petition challenged a notice dated 10.04.2024 issued under Section 148 of the Income Tax Act, 1961, by the Income Tax Officer, Ward 4(3), Jalandhar, and any consequential proceedings. The assessment year(s) are not explicitly stated. The procedural history is limited to the filing of the writ petition and the subsequent agreement between the parties.
What were the issues?
1. Whether the notice dated 10.04.2024 issued under Section 148 of the Income Tax Act, 1961, and consequential proceedings are liable to be quashed? (Question of law) Assessee's Contention: The petitioner relies on a previous judgment of the High Court dated 10.09.2026 in CWP-15791-2024 – Jyoti Sareen vs. Union of India and others, seeking similar relief. Revenue's Contention: The respondent (Income Tax Officer) agrees with the petitioner that the petitioner is entitled to the same relief as granted in the aforementioned Jyoti Sareen case. No specific arguments were recorded for the revenue beyond this consensus.
Which sections of the Income-tax Act were involved?
AI-generated summary — verify with the full judgment below
IN THE HIGH COURT OF PUNJAB AND HARYANA AT CHANDIGARH Sr. No.167 CWP-28427-2025 Date of decision: 10.09.2026 Harbhajan Singh ….Petitioner Versus Income Tax Officer, Ward 4(3), Jalandhar ….Respondent CORAM: HON’BLE MR. JUSTICE DEEPAK SIBAL HON’BLE MR. JUSTICE SUNISH BINDLISH Present: Mr. S.K. Mukhi, Advocate for the petitioner. Mr. Ranvijay Singh, Sr. Standing Counsel with Mr. Vidul Kapoor, Jr. Standing Counsel for the respondent. * * * 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 10.04.2024 issued to the petitioner under Section 148 of the Income Tax Act, 1961, alongwith consequential proceedings, if any. (DEEPAK SIBAL) JUDGE (SUNISH BINDLISH) JUDGE September 10, 2026 Jyoti 1 Whether speaking/reasoned Yes/No Whether reportable Yes/No JYOTI SHARMA 2026.09.13 14:07 I attest to the accuracy and authenticity of this document
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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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