RKV INFRAPROJECTS PRIVATE LIMITED AY 2021 TO 22 vs. DEPUTY ASSISTANT COMMISSIONER OF INCOME TAX, CENTRAL 1, CHANDIGARH

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CWP/30666/2026HC Punjab & HaryanaPHHC01158992202618 September 2026Bench: MR. JUSTICE SUNISH BINDLISH,MR. JUSTICE DEEPAK SIBAL1 pages
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What did the High Court hold?

The High Court of Punjab & Haryana at Chandigarh allowed the petition. The Court, in light of the consensus between the parties, granted the same relief as had been previously 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 12.08.2024 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 to follow a precedent set by the same court, the relief granted in that precedent should be extended. The operative direction was the quashing of the notice and consequential proceedings.

What were the facts?

The petitioner, RKV Infraprojects Private Limited, filed a writ petition before the High Court of Punjab & Haryana at Chandigarh. The petition challenged a notice dated 12.08.2024 issued under Section 148 of the Income Tax Act, 1961, and 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 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 notice dated 12.08.2024 issued under Section 148 of the Income Tax Act, 1961, to the petitioner is valid and sustainable in law? Assessee's contention: The petitioner sought the same relief as granted in Jyoti Sareen's case, implying the notice was likely challenged on grounds similar to that case, which often involve procedural infirmities or lack of proper satisfaction for reopening assessment. The petitioner agreed that the relief granted in Jyoti Sareen's case should apply. Revenue's contention: The revenue, through its counsel, agreed to the petitioner being entitled to the same relief as granted in Jyoti Sareen's case, indicating no opposition to quashing 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

IN THE HIGH COURT OF PUNJAB & HARYANA AT CHANDIGARH Sr. No.139 CWP-30666-2026 Date of decision: 18.09.2026 RKV INFRAPROJECTS PRIVATE LIMITED ..... Petitioner Versus THE DEPUTY ASSISTANT COMMISSIONER OF INCOME TAX, CENTRAL 1, CHANDIGARH AND ORS ..... Respondent(s) 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 with Mr. Vaibhav Gupta, Jr. Standing counsel and Ms. Kavita, Advocate, for the respondents. * * * DEEPAK SIBAL, J. 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 12.08.2024 issued to the petitioner under Section 148 of the Income Tax Act, 1961, alongwith consequential proceedings, if any. (DEEPAK SIBAL) JUDGE 18.09.2026 (SUNISH BINDLISH) Jyoti 1

JUDGE Whether speaking/reasoned : Yes / No Whether reportable : Yes / No JYOTI SHARMA 2026.09.21 12:07 I attest to the accuracy and authenticity of this document

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