VINOD KUMAR ALIAS VINOD KUMAR SAMRA vs. ASSISTANT COMMISSIONER OF INCOME TAX AND OTHERS
What did the High Court hold?
The High Court held that the impugned notice dated April 18, 2024, issued by the Jurisdictional Assessing Officer under Section 148 of the Income Tax Act, 1961, was liable to be quashed. This decision was based on the law laid down in two previous judgments of the same court, namely *Jatinder Singh Bhangu Vs. Union of India* and *Jasjit Singh Vs. Union of India*. In those judgments, the court had ruled that notices issued in a "faceless assessment" manner, contrary to the prevailing notifications, were invalid. The court found that the respondents did not dispute that the petitioner's case fell within the ambit of these precedents. Consequently, the court quashed the notice and granted liberty to the respondents to proceed against the petitioner in accordance with the law. No other issues were expressly left undecided.
What were the facts?
The petitioner, Vinod Kumar, challenged a notice dated April 18, 2024, issued under Section 148 of the Income Tax Act, 1961, by the Jurisdictional Assessing Officer. The petitioner contended that the notice was invalid because it was issued in a "faceless assessment" manner, which was not permissible under the notification dated March 29, 2022, issued by the Ministry of Finance. The petitioner relied on two previous judgments of the High Court of Punjab and Haryana in support of this argument. The respondents, the Income Tax Department, did not dispute the facts and conceded that the petitioner's case was covered by the aforementioned judgments.
What were the issues?
1. Whether the notice issued under Section 148 of the Income Tax Act, 1961, is invalid on the ground that it was issued in a "faceless assessment" manner, contrary to the notification dated March 29, 2022, issued by the Ministry of Finance? (Question of law and fact) Assessee's Contention: The petitioner argued that the impugned notice, issued by the Jurisdictional Assessing Officer, was invalid as it was issued through a faceless assessment procedure, which was not authorized by the relevant notification. The petitioner relied on the High Court's decisions in *Jatinder Singh Bhangu Vs. Union of India* (CWP-15745-2024) and *Jasjit Singh Vs. Union of India* (CWP-21509-2023). Revenue's Contention: The respondents conceded that the petitioner's case was covered by the judgments rendered by the High Court in *Jatinder Singh Bhangu* and *Jasjit Singh*.
Which sections of the Income-tax Act were involved?
AI-generated summary — verify with the full judgment below
CWP-21412-2
IN THE Vinod Kumar Assistant Com
CORAM : H
H
Present : M M fo
M
M
fo
DEEPAK SIB
C dated 18.04.20 under Section challenge rais issued by the done because 11), issued by notice could ha
In petitioner plac i. CWP India 2025 (O&M) Sr. No.156
E HIGH COURT OF PUNJAB CHANDIGARH
CWP-2141 Date of De
@ Vinod Kumar Samra Versus mmissioner of Income Tax and ot
HON’BLE MR. JUSTICE DEEPA HON’BLE MS. JUSTICE LAPITA Mr. Sahil Jain, Advocate and Mr. Nikhil Goyal, Advocate, or the petitioner. Mr. Varun Issar, Senior Standing Ms. Jaswinder Pridhi Sandhu, Ad or the Income Tax Department-re *** BAL, J. (Oral)
Challenge made through the ins 024 (Annexure P-6) 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 dat the Ministry of Finance, Govern 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 12-2025 (O&M) ecision : 29.07.2025
…Petitioner
thers
…Respondents AK SIBAL A BANERJI Cousnel and dvocate, espondents. 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 ted 29.03.2022 (Annexure P- nment of India, the impugned faceless assessment. sion, learned counsel for the o judgments of this Court:- 2024; and VANDANA 2025.08.02 12:23 I attest to the accuracy and integrity of this document
CWP-21412-2
ii. CWP other
L that the case o through the af Benches of thi
In Jatinder Sing dated 18.04.20 Officer, is here the petitioner i
T
July 29, 2025 vandana
Whether speak Whether repor 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 ( 024 (Annexure P-6), issued by eby quashed with liberty to the r in accordance with law. he petition is allowed in the abov
(DEEPA
J (LAPIT
J
5
king/reasoned :
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 2025.08.02 12:23 I attest to the accuracy and integrity of this document
More judgments on Section 148
- ACIT Central Bilaspur, Bilaspur vs Arun Kumar Agrawal, SaktiITSSA 26/RPR/2025[2018-19]Status: Disposed21 Oct 2026AY 2018-19
- Vinod Agrawal, Kawardha vs Assisstant Commissioner of Income Tax…ITA 666/RPR/2026[2019-20]Status: Heard21 Oct 2026AY 2019-20
- Sar Business Tradelink Private Limited… vs Income Tax Officer, Ward - 1(2), RaipurITA 599/RPR/2026[2014-15]Status: Heard21 Oct 2026AY 2014-15
- Neo Incorporation, Rajkot vs DCIT Circle- 1(2), RajkotITA 471/RJT/2026[2012-2013]Status: Disposed21 Oct 2026AY 2012-2013
- Adj Agri International LLP, Rajkot vs The Income Tax Officer, Ward-1(1)(1), RajkotITA 1198/RJT/2026[2018-19]Status: Disposed21 Oct 2026AY 2018-19
Latest GST High Court judgments
Search GST case law →- Santa Singh vs. SuperintendentUttarakhand · 27 Oct 2026
- Azaad Builders vs. Assistant Commissioner SGSTUttarakhand · 27 Oct 2026
- Sujit Paswan @ Sujit Pasman vs. The State Of BiharPatna · 27 Oct 2026
- M/S Kalra Traders vs. Union Of INDIAUttarakhand · 26 Oct 2026
- Ms Isoft vs. The Commissioner State TaxUttarakhand · 26 Oct 2026