PCIT ROHTAK vs. M/S PALIWAL OVERSEAS PVT LTD
What did the High Court hold?
The High Court held that the present appeal is covered by the judgment dated 03.10.2024 passed by a Co-ordinate Bench in ITA-73-2024, which involved the same appellant and respondent. The reasoning was based on the fair admission by the learned counsel for the appellant that the appeal was indeed covered by the earlier decision. Consequently, the High Court dismissed the present appeal in terms of the aforementioned judgment. The ratio decidendi is that appeals that are factually and legally identical to a previously decided case by a co-ordinate bench should be disposed of in line with that precedent, promoting judicial efficiency and consistency. No specific issues were decided on merits in this appeal; it was disposed of based on concession.
What were the facts?
The appeal was filed by the Principal Commissioner of Income Tax, Rohtak (appellant) against M/s Paliwal Overseas Pvt. Ltd. (respondent). The appeal was filed before the High Court of Punjab and Haryana at Chandigarh. The assessment years are not specified in the judgment. The appellant's counsel admitted that the present appeal was covered by a previous judgment of a Co-ordinate Bench dated 03.10.2024 in ITA-73-2024, which also involved the Principal Commissioner of Income Tax, Rohtak versus M/s Paliwal Overseas Pvt. Ltd. Based on this admission, the High Court dismissed the present appeal.
What were the issues?
1. Whether the present appeal is covered by the judgment dated 03.10.2024 passed by a Co-ordinate Bench in ITA-73-2024 - Principal Commissioner of Income Tax, Circle, Rohtak Vs. M/s Paliwal Overseas Pvt. Ltd. (Question of fact). Assessee's Contention: Not recorded as the assessee is the respondent and no arguments were presented on its behalf. Revenue's Contention: The learned counsel for the appellant (Revenue) fairly admitted that this appeal is covered against the appellant by the judgment dated 03.10.2024 passed by a Co-ordinate Bench in ITA-73-2024 - Principal Commissioner of Income Tax, Circle, Rohtak Vs. M/s Paliwal Overseas Pvt. Ltd. The Revenue relied on the principle of precedent and judicial discipline in acknowledging the binding nature of the earlier judgment.
AI-generated summary — verify with the full judgment below
IN THE HIGH COURT OF PUNJAB AND HARYANA AT CHANDIGARH 207/2 ITA-75-2024 Date of Decision: 15.07.2026 Principal Commissioner of Income Tax, Rohtak ....Appellant Versus M/s Paliwal Overseas Pvt. Ltd. ....Respondent CORAM: HON’BLE MR. JUSTICE DEEPAK SIBAL HON’BLE MS. JUSTICE RUPINDERJIT CHAHAL Present: Ms. Gauri Neo Rampal, Advocate (through VC) for the appellant. ***** DEEPAK SIBAL
, J (ORAL)
Learned counsel for the appellant fairly admits that this appeal is covered against the appellant by the judgment dated 03.10.2024 passed by a Co-ordinate Bench in ITA-73-2024 - Principal Commissioner of Income Tax, Circle, Rohtak Vs. M/s Paliwal Overseas Pvt. Ltd. 2. In the light of the afore fair stand taken on behalf of the appellant before us, the present appeal is also dismissed in terms of the judgment dated 03.10.2024 passed in ITA-73-2024 - Principal Commissioner of Income Tax, Circle, Rohtak Vs. M/s Paliwal Overseas Pvt. Ltd. (DEEPAK SIBAL) JUDGE (RUPINDERJIT CHAHAL) 15.07.2026 JUDGE D.Bansal Whether speaking/reasoned : Yes/No Whether reportable : Yes/No DINESH BANSAL 2026.07.17 15:48 I attest to the accuracy and integrity of this document Chandigarh
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