SURINDER PAL SINGH vs. INCOME TAX OFFICER AND OTHERS
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 Court quashed the impugned notice dated 24.03.2024 issued to the petitioner under Section 148 of the Income Tax Act, 1961, and any consequential proceedings that may have arisen therefrom. The reasoning was based on the mutual agreement of the parties to follow the precedent set in the Jyoti Sareen case. The operative direction was the quashing of the notice and consequential proceedings. No issue was expressly left undecided. The ratio decidendi is that where parties agree to be bound by a prior judgment of the same court on similar facts, the court will grant similar relief.
What were the facts?
The petitioner, Surinder Pal Singh, filed a writ petition (CWP-6643-2025) before the High Court of Punjab & Haryana at Chandigarh. The petition challenged a notice dated 24.03.2024 issued to the petitioner under Section 148 of the Income Tax Act, 1961, and any consequential proceedings. The Income Tax Officer and others were the respondents. The parties, including the petitioner and the respondents (Income Tax Department), agreed that the petitioner should receive the same relief as granted in a previous judgment by the same Court dated 10.09.2026 in CWP No.15791 of 2024, titled Jyoti Sareen Vs. Union of India and others. The assessment year(s) are not explicitly stated in the judgment.
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) dated 10.09.2026, concerning a notice issued under Section 148 of the Income Tax Act, 1961? 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 legal provisions or precedents were cited by the petitioner's counsel in this judgment. Revenue's Contention: The respondents, represented by the Senior Standing Counsel and Junior Standing Counsel for the Income Tax Department, also agreed to the consensus that the petitioner should receive the same relief as granted in the Jyoti Sareen case. No specific legal provisions or precedents were cited by the revenue's counsel in this judgment.
Which sections of the Income-tax Act were involved?
AI-generated summary — verify with the full judgment below
IN THE HIGH COURT OF PUNJAB & HARYANA AT CHANDIGARH
(Sr. No.117 )
CWP-6643-2025 (O&M)
Date of decision : 15.09.2026
SURINDER PAL SINGH .....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 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
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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