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

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CWP/860/2025HC Punjab & HaryanaPHHC01005464202511 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, comprising Hon'ble Mr. Justice Deepak Sibal and Hon'ble Mr. Justice Sunish Bindlish, allowed the petition. The court noted a consensus between the learned counsel for the parties 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 court quashed the impugned notice dated 14.02.2024 issued to the petitioner under Section 148 of the Income Tax Act, 1961, along with any consequential proceedings. The ratio decidendi is that if a similar issue concerning a Section 148 notice has been decided in favour of an assessee in a previous judgment by the same court, and the revenue agrees to the same relief, the current petition will be allowed in terms of the precedent.

What were the facts?

The petitioner, KBB Nuts Pvt. Ltd., has filed a writ petition (CWP-860-2025) before the High Court of Punjab and Haryana at Chandigarh. The respondents are the ACIT/DCIT, Central Circle, Amritsar, and others. The petitioner sought relief similar to that granted in a previous judgment by the same court dated 10.09.2026 in CWP-15791-2024, titled Jyoti Sareen vs. Union of India and others. The impugned action under challenge is a notice dated 14.02.2024 issued to the petitioner under Section 148 of the Income Tax Act, 1961, and any consequential proceedings arising from it. The assessment year(s) are not explicitly stated.

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) concerning the notice issued under Section 148 of the Income Tax Act, 1961? Assessee's Contention: The petitioner's counsel agreed that the petitioner would be entitled to the same relief as granted in the aforementioned Jyoti Sareen case. No specific arguments were detailed, but the consensus implies the petitioner sought to quash the Section 148 notice based on the precedent. Revenue's Contention: The revenue's counsel agreed to the consensus reached by the parties. No specific arguments were detailed, but their agreement suggests they did not oppose the application of the Jyoti Sareen judgment to the present case.

Which sections of the Income-tax Act were involved?

Section 148

AI-generated summary — verify with the full judgment below

CWP-860-2025 (O&M) 219 IN THE HIGH COURT OF PUNJAB AND HARYANA AT CHANDIGARH CWP-860-2025 (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 14.02.2024 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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