SATWANT KAUR vs. ASSISTANT COMMISSIONER OF INCOME TAX AND OTHERS

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CWP/23315/2025HC Punjab & HaryanaPHHC01126307202512 August 2025Author: MR. JUSTICE DEEPAK SIBAL,MS. JUSTICE LAPITA BANERJI2 pages
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What did the High Court hold?

The High Court allowed the petition. It quashed the impugned notice dated 17.06.2025 issued by the Jurisdictional Assessing Officer. The Court reasoned that the case was covered by its own previous judgments in Jatinder Singh Bhangu and Jasjit Singh (supra), which had dealt with similar challenges to Section 148 notices issued in contravention of the faceless assessment scheme. The revenue had not disputed this position. The quashing of the notice was with liberty to the respondents to proceed against the petitioner in accordance with law. No other issue was expressly left undecided.

What were the facts?

The petitioner, Satwant Kaur, challenged a notice issued under Section 148 of the Income Tax Act, 1961, by the Jurisdictional Assessing Officer (JAO). The challenge was based on the assertion that the impugned notice could only have been issued in terms of a notification dated 29.03.2022, which mandated faceless assessment. The petitioner argued that the notice, issued by the JAO, was therefore invalid. The revenue did not dispute that the petitioner's case was covered by previous judgments of the High Court.

What were the issues?

1. Whether the notice issued under Section 148 of the Income Tax Act, 1961, by the Jurisdictional Assessing Officer is invalid because it was not issued in accordance with the faceless assessment scheme notified on 29.03.2022. Assessee's contention: The impugned notice issued by the JAO is invalid as it should have been issued under the faceless assessment scheme as per the notification dated 29.03.2022. The assessee relied on the High Court 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 revenue conceded that the petitioner's case was covered by the aforesaid two judgments rendered by the High Court in Jatinder Singh Bhangu and Jasjit Singh (supra).

Which sections of the Income-tax Act were involved?

Section 148

AI-generated summary — verify with the full judgment below

CWP-23315 o

IN THE Satwant Kaur Assistant Com

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DEEPAK SIB

C dated 17.06.20 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.133

E HIGH COURT OF PUNJAB CHANDIGARH

CWP-2331 Date of De

Versus mmissioner of Income Tax, Circle

HON’BLE MR. JUSTICE DEEPA HON’BLE MS. JUSTICE LAPITA Mr. Vishav Bharti Gupta, Advoca or the petitioner. Mr. Ranvijay Singh, Sr. Standing Ms. Nikita Garg, Jr. Standing Cou or respondent-Income Tax Depar *** 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 15 of 2025 (O&M) ecision : 12.08.2025

…Petitioner

e -1, Ludhiana and others

…Respondents AK SIBAL A BANERJI ate, Counsel and unsel, rtment. 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 2025.08.13 14:43 I attest to the accuracy and integrity of this document

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L that the case o through the af Benches of thi

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In Jatinder Sing dated 17.06.20 Officer, is here the petitioner i

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August 12, 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 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 2025.08.13 14:43 I attest to the accuracy and integrity of this document

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