SAMPOORNA FEEDS PRIVATE LIMITED vs. INCOME TAX OFFICER AND OTHERS
What did the High Court hold?
The High Court held that the petitioner would be entitled to the same relief as had been granted in the judgment dated 10.09.2026 passed 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 29.03.2025, issued to the petitioner under Section 148 of the Income Tax Act, 1961, was quashed, along with any consequential proceedings that may have arisen therefrom. The reasoning is based on the agreement of both parties to follow the precedent set in the Jyoti Sareen case. The ratio decidendi is that where parties agree to parity with a prior judgment on similar facts and issues, the court will grant the same relief. No issue was expressly left undecided.
What were the facts?
The petitioner, Sampoorna Feeds Private Limited, filed a writ petition before the High Court of Punjab and Haryana at Chandigarh. The petition challenged a notice dated 29.03.2025 issued under Section 148 of the Income Tax Act, 1961, and any consequential proceedings. The parties, including the petitioner and the revenue (Income Tax Officer and others), agreed that the petitioner should receive the same relief as granted in a previous judgment by the same court on 10.09.2026 in CWP-15791-2024 (Jyoti Sareen vs. Union of India and others). The assessment year(s) are not explicitly stated in the judgment. The procedural history involves the filing of the writ petition and the subsequent consensus between the parties.
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, concerning a notice issued under Section 148 of the Income Tax Act, 1961? Assessee's Contention: The petitioner, through its counsel, agreed that it would be entitled to the same relief as granted in the aforementioned Jyoti Sareen case. No specific authorities or precedents were named by the petitioner in this regard, other than relying on the principle of parity with the cited judgment. Revenue's Contention: The revenue, through its Senior Standing Counsel, also agreed to the petitioner receiving the same relief as granted in the Jyoti Sareen case. No specific arguments or reliance on authorities were recorded for the revenue, other than their consensus on the outcome based on the prior judgment.
Which sections of the Income-tax Act were involved?
AI-generated summary — verify with the full judgment below
CWP-29006-2025 (O&M) 177 IN THE HIGH COURT OF PUNJAB AND HARYANA AT CHANDIGARH CWP-29006-2025 (O&M) Date of decision : 14.09.2026 Sampoorna Feeds Private Limited ...Petitioner Versus Income Tax Officer and others ...Respondents CORAM: HON’BLE MR. JUSTICE DEEPAK SIBAL HON’BLE MR. JUSTICE SUNISH BINDLISH Present: Mr.J.S. Bhasin, Advocate for the petitioner. (through V.C.). Mr.Ranvijay Singh, Sr. Standing Counsel 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 29.03.2025 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
More judgments on Section 148
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- Sar Business Tradelink Private Limited… vs Income Tax Officer, Ward - 1(2), RaipurITA 599/RPR/2026[2014-15]Status: Heard21 Oct 2026AY 2014-15
- Neo Incorporation, Rajkot vs DCIT Circle- 1(2), RajkotITA 471/RJT/2026[2012-2013]Status: Disposed21 Oct 2026AY 2012-2013
- 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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