RAJESH GOYAL vs. NATIONAL FACELESS ASSESMENT CENTRE INCOME TAX DEPARTMENT

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CWP/377/2025HC Punjab & HaryanaPHHC01003545202513 January 2025Author: MR. JUSTICE ARUN PALLI,MRS. JUSTICE SUDEEPTI SHARMA1 pages
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What did the High Court hold?

The High Court allowed the petition in terms of the consent of the parties. The court found that both the petitioner and the respondents agreed that the petitioner should receive the same relief as had been granted in a previous judgment of the High Court dated 10.09.2026 in CWP-15791-2024 – Jyoti Sareen vs. Union of India and others. Following this consensus, the court quashed the impugned notice dated 27.07.2022 issued to the petitioner under Section 148 of the Income Tax Act, 1961, and all consequential proceedings. The ratio decidendi is that where parties consent to follow a previous binding precedent of the same court, the court will grant the same relief to the petitioner.

What were the facts?

The petitioner, Rajesh Goyal, filed a writ petition before the High Court of Punjab and Haryana. The respondents were the Faceless Assessment Centre, Income Tax Department. The petition challenged an action taken by the Income Tax Department, specifically a notice dated 27.07.2022 issued to the petitioner under Section 148 of the Income Tax Act, 1961, along with consequential proceedings. The High Court noted that the parties agreed to the petitioner being entitled to the same relief as granted in a previous judgment of the same court dated 10.09.2026 in CWP-15791-2024 – Jyoti Sareen vs. Union of India and others. This previous judgment had granted relief based on the case of Jyoti Sareen.

What were the issues?

1. Whether the impugned notice dated 27.07.2022 issued to the petitioner under Section 148 of the Income Tax Act, 1961, and the consequential proceedings are liable to be quashed? (Question of law and fact, concerning Section 148 of the Income Tax Act, 1961). Assessee's Contention: The assessee argued that they should be entitled to the same relief as granted in the case of Jyoti Sareen vs. Union of India and others (CWP-15791-2024), based on a previous judgment of the High Court dated 10.09.2026. The assessee sought the quashing of the notice under Section 148 and any consequential proceedings. Revenue's Contention: The revenue, through the Sr. Standing Counsel, agreed that the petitioner would be entitled to the same relief as granted in the aforementioned Jyoti Sareen case. The revenue consented to the petition being allowed in terms of the previous judgment.

Which sections of the Income-tax Act were involved?

Section 148

AI-generated summary — verify with the full judgment below

108 108 108 108

IN T IN T IN T IN T

RAJESH GOY RAJESH GOY RAJESH GOY RAJESH GOY NATIONAL F NATIONAL F NATIONAL F NATIONAL F DEPARTMEN DEPARTMEN DEPARTMEN DEPARTMEN

CORAM: CORAM: CORAM: CORAM: HO HO

HO HO

Present : M M fo (T

**

DEEPAK SIB DEEPAK SIB DEEPAK SIB DEEPAK SIB

1.

Le also be entitled this Court date Union of India

2.

In terms of Jyoti notice dated 2 Income Tax Ac

11.

09 11.09 11.09 11.09.2026 .2026 .2026 .2026 Vandana yadav

THE HIGH COURT OF PUNJA THE HIGH COURT OF PUNJA THE HIGH COURT OF PUNJA THE HIGH COURT OF PUNJA AT CHANDIGARH AT CHANDIGARH AT CHANDIGARH AT CHANDIGARH

CW CW CW CW Da Da Da Da

YAL YAL YAL YAL

VERSUS VERSUS VERSUS VERSUS FACELESS ASSESMENT CEN FACELESS ASSESMENT CEN FACELESS ASSESMENT CEN FACELESS ASSESMENT CEN NT NT NT NT

ON'BLE MR. JUSTICE ON'BLE MR. JUSTICE ON'BLE MR. JUSTICE ON'BLE MR. JUSTICE DEEP DEEP DEEP DEEP ON’BLE MR. ON’BLE MR. ON’BLE MR. ON’BLE MR. JUSTICE SUNI JUSTICE SUNI JUSTICE SUNI JUSTICE SUNI Mr. Alok Mittal, Advocate, for the Ms. Gauri Neo Rampal, Sr. Standi r the respondents-Income Tax D Through Video Conferencing) *** BAL AL BAL AL, J. , J. , J. , J.(O (O (O (Oral ral ral ral) earned counsel for the parties a d to the same relief as has been ed 10.09.2026 passed in CWP- a and others. n the light of the above consen i Sareen’s case (supra), resulting 27.07.2022 issued to the petitio ct, 1961 alongwith consequential

Whether speaking/reasoned. : Ye Whether Reportable. : Ye AB AND HARYANA AB AND HARYANA AB AND HARYANA AB AND HARYANA H WP WP WP WP-377 377 377 377-2025 2025 2025 2025 ate of Decision : ate of Decision : ate of Decision : ate of Decision : 11.09. 11.09. 11.09. 11.09.2026 2026 2026 2026

...PETITIONER ...PETITIONER ...PETITIONER ...PETITIONER NTRE INCOME TAX NTRE INCOME TAX NTRE INCOME TAX NTRE INCOME TAX

...RESPONDENTS ...RESPONDENTS ...RESPONDENTS ...RESPONDENTS PAK SIBAL PAK SIBAL PAK SIBAL PAK SIBAL ISH BINDLISH ISH BINDLISH ISH BINDLISH ISH BINDLISH e petitioner. ing Counsel Department. agree that the petitioner would n granted through a judgment of -15791-2024 – Jyoti Sareen vs. nsus, the petition is allowed in g in quashing of the impugned oner under Section 148 of the l proceedings, if any. (DEEPAK SIBAL DEEPAK SIBAL DEEPAK SIBAL DEEPAK SIBAL)

JUDGE JUDGE JUDGE JUDGE (SUNISH BINDLISH) (SUNISH BINDLISH) (SUNISH BINDLISH) (SUNISH BINDLISH)

JUDGE JUDGE JUDGE JUDGE es/No es/No d f . n d e VANDANA YADAV 2026.09.17 12:00 I attest to the accuracy and integrity of this document

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