SARABJIT SINGH vs. DEPUTY COMMISSIONER OF INCOME TAX AND OTHERS

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CWP/6598/2025HC Punjab & HaryanaPHHC01036642202510 March 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 24.03.2024 issued to the petitioner under Section 148 of the Income Tax Act, 1961, along with any consequential proceedings, was quashed. The reasoning is based on the mutual agreement of the parties to follow the precedent set in the Jyoti Sareen case. The ratio decidendi is that where parties agree to follow a prior judgment of the High Court on similar facts, the court will grant similar relief. All pending miscellaneous applications were also disposed of.

What were the facts?

The petitioner, Sarabjit Singh, challenged a notice dated 24.03.2024 issued under Section 148 of the Income Tax Act, 1961, and any consequential proceedings. The petitioner and the respondents, the Deputy Commissioner of Income Tax and others, agreed that the petitioner should receive the same relief as granted in a previous High Court judgment dated 10.09.2026 in CWP No.15791 of 2024, titled Jyoti Sareen Vs. Union of India and others. The assessment year(s) and the specific amount in dispute are not recorded in the judgment. The procedural history is limited to the filing of this writ petition challenging the Section 148 notice.

What were the issues?

1. Whether the petitioner is entitled to the same relief as granted in Jyoti Sareen Vs. Union of India and others (CWP No.15791 of 2024)? (Question of law). Assessee's Contention: The petitioner's counsel agreed that the petitioner should be entitled to the same relief as granted in the aforementioned Jyoti Sareen case. Revenue's Contention: The revenue's counsel also agreed to this consensus. No specific authorities, circulars, or precedents were named by either side, other than the reference to the Jyoti Sareen judgment.

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.246 )

CWP-6598-2025 (O&M)

Date of decision : 15.09.2026

SARABJIT SINGH .....Petitioner

Versus

DEPUTY COMMISSIONER OF INCOME TAX 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. Varun Issar, Senior Standing Counsel,

Ms. Nikita Garg, 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 24.03.2024 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 16:12 I attest to the accuracy and authenticity of this order. Chandigarh

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