NORTHWIND FOREX PRIVATE LIMITED vs. INCOME TAX OFFICER AND OTHERS

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CWP/24167/2025HC Punjab & HaryanaPHHC01132422202521 August 2025Author: MR. JUSTICE DEEPAK SIBAL,MS. JUSTICE LAPITA BANERJI2 pages
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What did the High Court hold?

The High Court held that the case of the petitioner was covered by the law laid down in the two judgments previously rendered by co-ordinate Benches of the Court, namely Jatinder Singh Bhangu Vs. Union of India and others and Jasjit Singh Vs. Union of India and others. Consequently, the impugned notice issued under Section 148 of the Income Tax Act, 1961, by the Jurisdictional Assessing Officer, was quashed. The Court granted liberty to the respondents to proceed against the petitioner in accordance with law. No specific issue was left undecided.

What were the facts?

The petitioner, Northwind Forex Private Limited, filed a writ petition challenging a notice issued under Section 148 of the Income Tax Act, 1961, by the respondent-Income Tax Officer, Ward 2(1), Chandigarh. The petitioner contended that the notice was invalid because it was issued in terms of a notification dated March 29, 2022, from the Ministry of Finance, Government of India, which mandated faceless assessment, and the notice was not issued in compliance with this. The petitioner relied on two previous judgments of the Punjab and Haryana High Court in support of its submission that the notice should have been issued by the Jurisdictional Assessing Officer.

What were the issues?

1. Whether the notice issued under Section 148 of the Income Tax Act, 1961, is invalid because it was not issued by the Jurisdictional Assessing Officer, contrary to the mandate of faceless assessment as per the notification dated March 29, 2022. Assessee's contention: The petitioner argued that the impugned notice was issued by the Jurisdictional Assessing Officer, which was impermissible in light of the notification dated March 29, 2022, mandating faceless assessment. The petitioner relied on the judgments in Jatinder Singh Bhangu Vs. Union of India and others (CWP-15745-2024) and Jasjit Singh Vs. Union of India and others (CWP-21509-2023). Revenue's contention: The respondent-Income Tax Department did not dispute the facts presented by the petitioner and conceded that the case was covered by the aforesaid two judgments rendered by co-ordinate Benches of the High Court.

Which sections of the Income-tax Act were involved?

Section 148

AI-generated summary — verify with the full judgment below

CWP-24167

IN THE Northwind For

Income Tax O

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Present : M fo

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DEEPAK SIB

C dated 09.06.20 under Section challenge rais issued by the done because i issued by the notice could ha

2.

In petitioner plac i. CWP India of 2025 (O&M) Sr. No.127

E HIGH COURT OF PUNJAB CHANDIGARH

CWP-2416 Date of De

rex Private Limited

Versus fficer, Ward 2(1), Chandigarh an HON’BLE MR. JUSTICE DEEPA HON’BLE MS. JUSTICE LAPITA Mr. Umang Goyal, Advocate, or the petitioner. Mr. Yogesh Putney, Sr. Standing Mr. Vidul Kapoor, Jr. Standing co Mr. Vaibhav Gupta, Advocate, or the respondent-Income Tax De *** BAL, J. (Oral)

Challenge made through the ins 025 (Annexure P-1) issued to the 148 of the Income Tax Act, 1 ed by the petitioner is that th Juri ictional Assessing Office in terms of the notification dated Ministry of Finance, Governm ave been issued only by way of f n support of his afore submiss es reliance on the following two P-15745-2024, titled Jatinder S a and others, decided on 19.07.2 B AND HARYANA AT H 67 of 2025 (O&M) ecision : 21.08.2025

…Petitioner nd others …Respondents AK SIBAL A BANERJI counsel, ounsel and epartment. stant petition is to the notice e petitioner by the respondents 1961. The primary ground of e impugned notice has been er which could have not been d 29.03.2022 (Annexure P-2), ment of India, the impugned faceless assessment. sion, learned counsel for the o judgments of this Court:- 2024; and VANDANA 2025.08.27 09:39 I attest to the accuracy and integrity of this document

CWP-24167

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L that the case o through the af Benches of thi

4.

In Jatinder Sing dated 09.06.20 Officer, is here the petitioner i

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August 21, 20 vandana

Whether speak Whether repor of 2025 (O&M) P-21509-2023, titled Jasjit Sin rs, decided on 29.07.2024. earned counsel for the responde of the petitioner is covered in his foresaid two judgments rendered is Court in Jatinder Singh Bhan n the light of the above, in ter gh Bhangu and Jasjit Singh ( 025 (Annexure P-1), issued by eby quashed with liberty to the r in accordance with law. he petition is allowed in the abov

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Yes/No rtable :

Yes/No gh Vs. Union of India and ents does not dispute the fact s favour by the law laid down d by two different co-ordinate ngu and Jasjit Singh (supra). rms of the law laid down in (supra), the impugned notice y the Juri ictional Assessing respondents to proceed against ve terms. AK SIBAL) JUDGE

TA BANERJI) JUDGE VANDANA 2025.08.27 09:39 I attest to the accuracy and integrity of this document

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