RAJAN GUPTA vs. INCOME TAX OFFICER, LUDHIANA
What did the High Court hold?
The High Court, in light of the consensus reached between the petitioner and the revenue, allowed the petition. The court held that the petitioner was entitled to the same relief as granted in the case of Jyoti Sareen vs. Union of India and others (CWP-15791-2024) dated 10.09.2026. Consequently, the notice dated 06.04.2022, issued to the petitioner under Section 148 of the Income Tax Act, 1961, and all consequential proceedings arising therefrom, were quashed. The ratio decidendi is that where parties agree to a specific outcome based on a prior binding precedent, the court will follow that precedent to grant similar relief. The operative direction was the quashing of the notice and consequential proceedings.
What were the facts?
The petitioner, through their counsel, agreed with the revenue that they should receive the same relief as granted in a previous judgment of the High Court dated 10.09.2026 in CWP-15791-2024, titled Jyoti Sareen vs. Union of India and others. This consensus led to the allowance of the present petition. The impugned notice dated 06.04.2022, issued to the petitioner under Section 148 of the Income Tax Act, 1961, along with any consequential proceedings, was quashed. The judgment does not specify the assessment year(s) or the amount in dispute.
What were the issues?
1. Whether the petitioner is entitled to the same relief as granted in Jyoti Sareen vs. Union of India and others (CWP-15791-2024) dated 10.09.2026, concerning a notice issued under Section 148 of the Income Tax Act, 1961? Assessee's contention: The petitioner argued, through their counsel, that they should be granted the same relief as was awarded in the aforementioned Jyoti Sareen case. No specific legal provisions or precedents were named by the petitioner's counsel in support of this argument, other than reliance on the prior judgment. Revenue's contention: The revenue, through its counsel, agreed with the petitioner's submission that the petitioner should be entitled to the same relief as granted in the Jyoti Sareen case. No specific legal provisions or precedents were named by the revenue's counsel.
Which sections of the Income-tax Act were involved?
AI-generated summary — verify with the full judgment below
CWP-34866-2024 (O&M) 220 IN THE HIGH COURT OF PUNJAB AND HARYANA AT CHANDIGARH CWP-34866-2024 (O&M) Date of decision : 16.09.2026 Rajan Gupta ...Petitioner Versus Income Tax Officer, Ludhiana ...Respondents CORAM: HON’BLE MR. JUSTICE DEEPAK SIBAL HON’BLE MR. JUSTICE SUNISH BINDLISH Present: Mr. S.K. Mukhi, Advocate for the petitioner. (through V.C.). Mr.Ranvijay Singh, Sr. Standing Counsel with Mr. Vidul Kapoor, 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 06.04.2022 issued to the petitioner under Section 148 of the Income Tax Act, 1961 alongwith consequential proceedings, if any. (DEEPAK SIBAL) JUDGE (SUNISH BINDLISH) JUDGE 16.09.2026 Harish Kumar Whether speaking / reasoned: Yes No Whether Reportable : Yes No
-1- HARISH KUMAR 2026.09.19 08:48 I attest to the accuracy and integrity of this document
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