SODHI SINGH vs. INCOME TAX OFFICER, PHAGWARA PUNJAB

PDF · subscribers
CWP/9745/2025HC Punjab & HaryanaPHHC01053838202514 September 2026Bench: MR. JUSTICE SUNISH BINDLISH,MR. JUSTICE DEEPAK SIBAL1 pages
AI SummaryAllowed

What did the High Court hold?

The High Court held 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). Based on the consensus between the parties, the Court allowed the petition. The impugned notice dated 26.03.2024, issued to the petitioner under Section 148 of the Income Tax Act, 1961, was quashed, along with any consequential proceedings that may have arisen therefrom. The reasoning is based on the agreement of the parties to follow the precedent set in the Jyoti Sareen case. The ratio decidendi is that where parties agree to parity with a prior judgment on similar facts and legal issues, the court will grant the same relief. No issues were expressly left undecided.

What were the facts?

The petitioner, Sodhi Singh, filed a writ petition (CWP-9745-2025) before the High Court of Punjab and Haryana at Chandigarh. The petition challenged a notice dated 26.03.2024 issued under Section 148 of the Income Tax Act, 1961, and any consequential proceedings. The respondent was the Income Tax Officer, Ward 1, Phagwara. Both parties, the petitioner and the revenue, 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, titled Jyoti Sareen vs. Union of India and others. The assessment year(s) and the specific amount in dispute are not recorded in the judgment.

What were the issues?

1. Whether the petitioner is entitled to the same relief as granted in the case of Jyoti Sareen vs. Union of India and others (CWP-15791-2024), concerning a notice issued under Section 148 of the Income Tax Act, 1961. Assessee's Contention: The petitioner argued that they should receive the same relief as granted in the aforementioned Jyoti Sareen case. No specific authorities, circulars, or precedents were named by the petitioner's counsel, but the argument was based on parity with the earlier judgment. Revenue's Contention: The revenue, through its Sr. Standing Counsel, agreed with the petitioner's submission that the petitioner should be granted the same relief as in the Jyoti Sareen case. The revenue did not present any opposing arguments or rely on any specific legal provisions or precedents.

Which sections of the Income-tax Act were involved?

Section 148

AI-generated summary — verify with the full judgment below

CWP-9745-2025 (O&M) 137 IN THE HIGH COURT OF PUNJAB AND HARYANA AT CHANDIGARH CWP-9745-2025 (O&M) Date of decision : 14.09.2026 Sodhi Singh ...Petitioner Versus Income Tax Officer, Ward 1, Phagwara ...Respondents CORAM: HON’BLE MR. JUSTICE DEEPAK SIBAL HON’BLE MR. JUSTICE SUNISH BINDLISH Present: Mr.S.K. Mukhi, Advocate for the petitioner. Mr.Ranvijay Singh, Sr. 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 26.03.2024 issued to the petitioner under Section 148 of the Income Tax Act, 1961 alongwith consequential proceedings, if any. (DEEPAK SIBAL) JUDGE (SUNISH BINDLISH) JUDGE 14.09.2026 Harish Kumar Whether speaking / reasoned: Yes No Whether Reportable : Yes No

-1- HARISH KUMAR 2026.09.17 19:53 I attest to the accuracy and integrity of this document

More judgments on Section 148

All 35,022 judgments and leading authorities on Section 148 →

Recent GST High Court judgments

Search GST case law →