ANIL YADAV vs. INCOME TAX OFFICER WARD 1 NARNAUL AND OTHERS

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CWP/21496/2025HC Punjab & HaryanaPHHC01117069202529 July 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 previous judgments 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, which was challenged on the grounds of being issued in a faceless assessment manner, was quashed. The Court granted liberty to the respondents (Income Tax Department) to proceed against the petitioner in accordance with law. The petition was allowed in the above terms.

What were the facts?

The petitioner, Anil Yadav, challenged a notice 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 as per a notification dated 29.03.2022 issued by the Ministry of Finance. The petitioner argued that the notice should have been issued only by the jurisdictional officer. To support this, the petitioner relied on two previous judgments of the High Court: Jatinder Singh Bhangu Vs. Union of India and others, decided on 19.07.2024, and Jasjit Singh Vs. Union of India and others, decided on 29.07.2025.

What were the issues?

1. Whether the notice issued under Section 148 of the Income Tax Act, 1961, by the Jurisdictional Assessing Officer in a "faceless assessment" manner is valid, considering the notification dated 29.03.2022. Assessee's Contention: The petitioner argued that the notice was invalid because it was issued through a faceless assessment process, which contravened the provisions of the notification dated 29.03.2022. The petitioner relied on the High Court's decisions in Jatinder Singh Bhangu Vs. Union of India and others and Jasjit Singh Vs. Union of India and others. Revenue's Contention: The respondent-Income Tax Department did not dispute the facts presented by the petitioner and conceded that the petitioner's case was covered by the aforementioned judgments 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-21496-2

IN THE Anil Yadav Income Tax O

CORAM : H

H

Present : M

fo

M fo

DEEPAK SIB

C dated 27.06.20 under Section challenge rais issued by the done because i issued by the notice could ha

2.

In petitioner plac i. CWP India ii. CWP other 2025 (O&M)

Sr. No.159

E HIGH COURT OF PUNJAB CHANDIGARH

CWP-2149 Date of De

… Versus fficer, Ward-1, Narnaul and othe

HON’BLE MR. JUSTICE DEEPA HON’BLE MS. JUSTICE LAPITA Mr. Kartik Bansal, Advocate, or the petitioner. Ms. Pridhi Sandhu, 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 P-21509-2023, titled Jasjit Sin rs, decided on 29.07.2024. B AND HARYANA AT H 96-2025 (O&M) ecision : 29.07.2025

…Petitioner

ers

…Respondents AK SIBAL A BANERJI 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 2025.08.02 12:23 I attest to the accuracy and integrity of this document

CWP-21496-2

3.

L that the case o through the af Benches of thi

4.

In Jatinder Sing dated 27.06.20 Officer, is here the petitioner i

5.

T

July 29, 2025 vandana

Whether speak Whether repor 2025 (O&M)

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

(DEEPA

J (LAPIT

J

5

king/reasoned :

Yes/No rtable :

Yes/No 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

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