SAPNA ARORA SINCE DECEASED THROUGH LEGAL HEIR ANJALI KAPOOR vs. INCOME TAX OFFICER AND OTHERS

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CWP/9427/2025HC Punjab & HaryanaPHHC01052294202503 April 2025Author: MR. JUSTICE ARUN PALLI,MRS. JUSTICE SUDEEPTI SHARMA1 pages
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What did the High Court hold?

The High Court held that the petitioner would be entitled to the same relief as granted in the judgment dated 10.09.2026 in CWP No.15791 of 2024 (Jyoti Sareen Vs. Union of India and others). Based on this consensus between the parties, the petition was allowed. The impugned notice dated 21.03.2024 issued to the petitioner under Section 148 of the Income Tax Act, 1961, along with any consequential proceedings, was quashed. The reasoning was based on the agreement of the parties to extend the relief granted in the precedent case. The ratio decidendi is that where parties agree to follow a binding precedent of the High Court concerning similar facts and issues, the court will grant the same relief. All pending miscellaneous applications were also disposed of.

What were the facts?

The petitioner, Sapna Arora (since deceased through legal heir Anjali Kapoor), filed a writ petition before the Punjab & Haryana High Court challenging a notice dated 21.03.2024 issued under Section 148 of the Income Tax Act, 1961, and any consequential proceedings. The respondents were the Income Tax Officer and others. The assessment year(s) are not explicitly stated. The procedural history involves the filing of the writ petition and the subsequent consensus reached between the parties.

What were the issues?

1. Whether the petitioner is entitled to the same relief as granted in a previous judgment of the High Court dated 10.09.2026 in CWP No.15791 of 2024 (Jyoti Sareen Vs. Union of India and others)? (Question of law and fact, turning on the applicability of precedent). Assessee's Contention: The petitioner, through their counsel, agreed that they would be entitled to the same relief as granted in the aforementioned Jyoti Sareen case. No specific authorities or precedents were named by the petitioner's counsel in support of this contention, other than the agreement to follow the precedent. Revenue's Contention: The revenue, represented by Senior Standing Counsel and Junior Standing Counsel, also agreed to the same relief being granted to the petitioner as in the Jyoti Sareen case. No specific authorities or precedents were named by the revenue's counsel.

Which sections of the Income-tax Act were involved?

Section 148

AI-generated summary — verify with the full judgment below

IN THE HIGH COURT OF PUNJAB & HARYANA AT CHANDIGARH

(Sr. No.129 )

CWP-9427-2025 (O&M)

Date of decision : 15.09.2026

SAPNA ARORA SINCE DECEASED THROUGH LEGAL HEIR ANJALI KAPOOR .....Petitioner

Versus

INCOME TAX OFFICER AND OTHERS ` .....Respondent(s)

CORAM : HON'BLE MR. JUSTICE DEEPAK SIBAL

HON'BLE MR. JUSTICE SUNISH BINDLISH

Present : Mr. Vishav Bharti Gupta, Advocate for the petitioner.

Mr. Ranvijay Singh, Senior Standing Counsel,

Mr. Vidul Kapoor, Junior Standing Counsel for

the respondent(s)-Income Tax Department.

* * * DEEPAK SIBAL, J. (Oral) (1) Learned counsel for the parties agree that the petitioner would also be entitled to the same relief as has been granted through a judgment of this Court dated 10.09.2026 passed in CWP No.15791 of 2024 - Jyoti Sareen Vs. Union of India and others. (2)

In the light of the above consensus, the petition is allowed in terms of Jyoti Sareen’s case (supra), resulting in quashing of the impugned notice dated 21.03.2024 issued to the petitioner under Section 148 of the Income Tax Act, 1961, along with consequential proceedings, if any. (3)

All pending miscellaneous applications, if any, also stand disposed of.

(DEEPAK SIBAL)

JUDGE

15.09.

2026

( SUNISH BINDLISH ) sunil yadav

JUDGE

Whether speaking/reasoned : Yes / No Whether reportable : Yes / No SUNIL YADAV 2026.09.17 11:55 I attest to the accuracy and authenticity of this order. Chandigarh

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