RAMAN SINGH GILL vs. ASSISTANT COMMISSIONER OF INCOME TAX AND OTHERS

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CWP/9865/2025HC Punjab & HaryanaPHHC01053201202511 September 2026Bench: MR. JUSTICE SUNISH BINDLISH,MR. JUSTICE DEEPAK SIBAL1 pages
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What did the High Court hold?

The High Court held that the petitioner is 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 this consensus between the parties, the petition was allowed. The impugned notice dated 30.03.2025, issued to the petitioner under Section 148 of the Income Tax Act, 1961, was quashed, along with any consequential proceedings. The reasoning is primarily based on the agreement between the petitioner and the revenue to follow the precedent set in the Jyoti Sareen case. The ratio decidendi is that where parties agree to a specific outcome based on a prior binding precedent, the court will uphold that agreement and grant the consequential relief. No issues were left undecided.

What were the facts?

The petitioner, Raman Singh Gill, challenged a notice dated 30.03.2025 issued under Section 148 of the Income Tax Act, 1961, along with any consequential proceedings. The respondent is the Assistant Commissioner of Income Tax, Circle 1(1), Chandigarh. The parties agreed that the petitioner should receive the same relief as granted in a previous judgment by the same court on 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 judgment. The procedural history involves the issuance of the Section 148 notice and the subsequent challenge through a writ petition.

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) decided on 10.09.2026, concerning a notice issued under Section 148 of the Income Tax Act, 1961? Assessee's contention: The petitioner relies on the consensus reached with the revenue that they are entitled to the same relief as granted in the aforementioned Jyoti Sareen case. No specific authorities or precedents are named by the petitioner's counsel, but the reliance is on the prior judgment. Revenue's contention: The revenue, through its learned counsel, agrees with the petitioner that the petitioner should be granted the same relief as in the Jyoti Sareen case. No specific arguments or authorities are recorded for the revenue, other than their agreement.

Which sections of the Income-tax Act were involved?

Section 148

AI-generated summary — verify with the full judgment below

CWP-9865-2025 (O&M) 127 IN THE HIGH COURT OF PUNJAB AND HARYANA AT CHANDIGARH CWP-9865-2025 (O&M) Date of decision : 11.09.2026 Raman Singh Gill ...Petitioner Versus Assistant Commissioner of Income Tax, ACIT/DCIT, Circle 1(1), Chandigarh

..Respondent(s) CORAM: HON’BLE MR. JUSTICE DEEPAK SIBAL HON’BLE MR. JUSTICE SUNISH BINDLISH Present: Mr. Abhinav Narang, Advocate for the petitioner. Ms. Urvashi Dhugga, Senior Standing Counsel with Mr. Vaibhav Gupta, Jr. Standing Counsel & Ms. Kavita, Advocate 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 30.03.2025 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 2026.09.12 15:43 I attest to the accuracy and integrity of this document

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