RKV INFRAPROJECTS PRIVATE LIMITED AY 2020 TO 21 vs. DEPUTY ASSISTANT COMMISSIONER OF INCOME TAX, CENTRAL 1, CHANDIGARH
What did the High Court hold?
The High Court allowed the petition in terms of the judgment passed in CWP-15791-2024 (Jyoti Sareen vs. Union of India and others). The Court quashed the impugned notice dated 24.03.2024 issued to the petitioner under Section 148 of the Income Tax Act, 1961, along with any consequential proceedings. The reasoning is based on the consensus between the parties that the petitioner should receive the same relief as granted in the cited precedent. The ratio decidendi is that if parties agree that a case is on all fours with a prior binding precedent, the same relief should be extended. The operative direction is the quashing of the Section 148 notice and consequential actions. No issue was expressly left undecided.
What were the facts?
The petitioner, RKV Infra Projects Pvt. Ltd., filed a writ petition before the High Court of Punjab and Haryana at Chandigarh challenging a notice dated 24.03.2024 issued under Section 148 of the Income Tax Act, 1961, along with any consequential proceedings. The respondents were the Deputy/Assistant Commissioner of Income Tax, Central 1, Chandigarh, and others. The parties agreed that the petitioner should receive the same relief as granted in a previous judgment of the same Court dated 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 provided text. The procedural history is limited to the filing of the writ petition and the agreement reached by the parties.
What were the issues?
1. Whether the notice dated 24.03.2024 issued under Section 148 of the Income Tax Act, 1961, and consequential proceedings are liable to be quashed, turning on the applicability of the principles laid down in the judgment of Jyoti Sareen vs. Union of India and others (dated 10.09.2026). Assessee's contention: The petitioner argued that it is entitled to the same relief as granted in the aforementioned Jyoti Sareen case. No specific arguments were detailed, but the consensus implies agreement with the outcome of the cited case. Revenue's contention: The revenue, represented by Sr. Standing Counsel and Advocate, agreed with the petitioner that the same relief should be granted. No specific arguments were detailed, but their agreement indicates no opposition to the relief sought based on the precedent.
Which sections of the Income-tax Act were involved?
AI-generated summary — verify with the full judgment below
CWP-30636-2026 (O&M) 136 IN THE HIGH COURT OF PUNJAB AND HARYANA AT CHANDIGARH CWP-30636-2026 (O&M) Date of decision : 18.09.2026 RKV Infra Projects Pvt. Ltd. ...Petitioner Versus Deputy/Assistant Commissioner of Income Tax, Central 1, Chandigarh and other ...Respondents CORAM: HON’BLE MR. JUSTICE DEEPAK SIBAL HON’BLE MR. JUSTICE SUNISH BINDLISH Present: Mr. Rochak Singla, Advocate for the petitioner. 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 24.03.2024 issued to the petitioner under Section 148 of the Income Tax Act, 1961 alongwith consequential proceedings, if any. (DEEPAK SIBAL) JUDGE (SUNISH BINDLISH) JUDGE 18.09.2026 Harish Kumar Whether speaking / reasoned: Yes No Whether Reportable : Yes No
-1- HARISH KUMAR 2026.09.22 14:02 I attest to the accuracy and integrity of this document
More judgments on Section 148
- ACIT Central Bilaspur, Bilaspur vs Arun Kumar Agrawal, SaktiITSSA 26/RPR/2025[2018-19]Status: Disposed21 Oct 2026AY 2018-19
- Vinod Agrawal, Kawardha vs Assisstant Commissioner of Income Tax…ITA 666/RPR/2026[2019-20]Status: Heard21 Oct 2026AY 2019-20
- 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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