RAJPREET SINGH DEOL vs. OFFICE OF THE INCOME TAX OFFICER

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CWP/3341/2025HC Punjab & HaryanaPHHC01018037202527 February 2025Bench: MR. JUSTICE DEEPAK SIBAL,MRS. JUSTICE SUDEEPTI SHARMA1 pages
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What did the High Court hold?

The High Court, in light of the consensus between the parties, allowed the petition. The court held that the petitioner was entitled to the same relief as had been granted in the judgment dated 10.09.2026 in CWP No. 15791 of 2024 (Jyoti Sareen Vs. Union of India and others). Consequently, the impugned notice dated 28.03.2023, issued to the petitioner under Section 148 of the Income Tax Act, 1961, along with any consequential proceedings, were quashed. The court also ordered that all pending miscellaneous applications, if any, stand disposed of. The ratio decidendi is that where parties agree to follow a precedent set by a coordinate bench of the same High Court, the court will grant similar relief.

What were the facts?

The petitioner, Rajpreet Singh Deol, filed a writ petition (CWP No. 3341 of 2025) challenging a notice dated 28.03.2023 issued under Section 148 of the Income Tax Act, 1961, and any consequential proceedings. The respondent was the Income Tax Officer. The parties agreed that the petitioner was entitled to the same relief as granted in a previous judgment by the High Court in CWP No. 15791 of 2024, titled Jyoti Sareen Vs. Union of India and others, decided on 10.09.2026. The High Court disposed of the matter based on this consensus.

What were the issues?

1. Whether the petitioner is entitled to the same relief as granted in Jyoti Sareen's case (CWP No. 15791 of 2024)? Assessee's Contention: The assessee argued that they should receive the same relief as granted in the case of Jyoti Sareen Vs. Union of India and others (CWP No. 15791 of 2024), as agreed by both parties. This implies that the impugned notice and consequential proceedings should be quashed. Revenue's Contention: The revenue, through its counsel, agreed with the assessee's submission that the petitioner is entitled to the same relief as granted in Jyoti Sareen's case. Therefore, the revenue did not contest the quashing of the notice and proceedings 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 (Sr. No. 104)

Rajpreet

Office of t

CORAM

Present :

DEEPAK (1) also be en this Cour Sareen Vs (2)

terms of J notice dat Income T (3)

disposed o

11.09.202 sunil yadav

Wh N THE HIGH COURT OF P AT CHANDI

Singh Deol Versus the Income Tax Officer M : HON'BLE MR. JUSTICE HON'BLE MR. JUSTICE Mr. Sunil K. Mukhi, Advoca for the petitioner (through VC Mr. Ranvijay Singh, Senior S Mr. Vidul Kapoor, Junior Sta the respondent(s)-Income Ta

* * * K SIBAL, J. (Oral) Learned counsel for the part ntitled to the same relief as has b rt dated 10.09.2026 passed in Vs. Union of India and others. In the light of the above co Jyoti Sareen’s case (supra), resu ted 28.03.2023 issued to the pe ax Act, 1961, along with conseq All pending miscellaneous of.

hether speaking/reasoned : Yes / No hether reportable : Yes / No PUNJAB & HARYANA IGARH

CWP No.3341 of 2025 Date of decision: 11.09.2026 .....Petitio ` .....Responde E DEEPAK SIBAL E SUDEEPTI SHARMA ate C). Standing Counsel, anding Counsel for ax Department. ties agree that the petitioner wo been granted through a judgment CWP No.15791 of 2024 - Jy onsensus, the petition is allowed ulting in quashing of the impugn etitioner under Section 148 of quential proceedings, if any. applications, if any, also sta ( DEEPAK SIBAL ) JUDGE ( SUDEEPTI SHARMA ) JUDGE o o

6 oner ents ould t of yoti d in ned the and SUNIL YADAV 2026.09.14 16:46 I attest to the accuracy and authenticity of this order. Chandigarh

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