KBB NUTS PRIVATE LIMITED vs. ACIT/DCIT CENTRAL CIRCLE AMRITSAR AND ANOTHER

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CWP/33983/2024HC Punjab & HaryanaPHHC01176614202411 September 2026Bench: MR. JUSTICE SUNISH BINDLISH,MR. JUSTICE DEEPAK SIBAL1 pages
AI SummaryAllowed

What did the High Court hold?

The High Court of Punjab and Haryana at Chandigarh, in light of the consensus reached between the learned counsel for the parties, allowed the petition. The court directed 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 13.03.2024, 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 where parties agree to follow a precedent set by the same court in a similar matter, the court will grant the same relief. No issues were expressly left undecided.

What were the facts?

The petitioner, KBB Nuts Pvt. Ltd., filed a writ petition before the High Court of Punjab and Haryana at Chandigarh. The respondents were the ACIT/DCIT, Central Circle, Amritsar, and others. The petitioner sought relief against a notice dated 13.03.2024 issued under Section 148 of the Income Tax Act, 1961, and any consequential proceedings. The parties, through their learned counsel, 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, titled Jyoti Sareen vs. Union of India and others. The assessment year(s) are not explicitly stated in the provided text.

What were the issues?

1. Whether the notice dated 13.03.2024 issued to the petitioner 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 argued that they are 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. No specific arguments against the notice itself were detailed, but the reliance on the precedent implies a challenge to its validity or applicability. Revenue's Contention: The revenue, through its senior standing counsel and junior standing counsel, agreed to the petitioner receiving the same relief as granted in the aforementioned Jyoti Sareen case. This indicates a consensus on the outcome without contesting the merits of the petitioner's claim in this specific instance.

Which sections of the Income-tax Act were involved?

Section 148

AI-generated summary — verify with the full judgment below

CWP-33983-2024 (O&M) 217 IN THE HIGH COURT OF PUNJAB AND HARYANA AT CHANDIGARH CWP-33983-2024 (O&M) Date of decision : 11.09.2026 KBB Nuts Pvt. Ltd. ...Petitioner Versus ACIT/DCIT, Central Circle, Amritsar and others ...Respondents CORAM: HON’BLE MR. JUSTICE DEEPAK SIBAL HON’BLE MR. JUSTICE SUNISH BINDLISH Present: Ms. Aditi Sabharwal, Advocate, Mr. Amanpreet Singh, Advocate and Mr. Himmat Singh, Advocate for the petitioner. Mr. Varun Issar, Senior Standing Counsel and Ms. Pridhi Sandhu, Jr. 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 13.03.2024 issued to the petitioner under Section 148 of the Income Tax Act, 1961 alongwith consequential proceedings, if any. (DEEPAK SIBAL) JUDGE (SUNISH BINDLISH) JUDGE 11.09.2026 Harish Kumar Whether speaking / reasoned: Yes No Whether Reportable : Yes No

-1- HARISH KUMAR 2026.09.14 18:06 I attest to the accuracy and integrity of this document

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