SANAT ENTERPRISES PRIVATE LIMITED vs. ASSISTANT COMMISSIONER OF INCOME TAX, CIRCLE 1(1), CHANDIGARH AND OTHERS

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CWP/18187/2025HC Punjab & HaryanaPHHC01100205202507 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 impugned notice issued under Section 148 of the Income Tax Act, 1961, by the Jurisdictional Assessing Officer was liable to be quashed. This decision was based on the law laid down in two previous judgments of the same court: Jatinder Singh Bhangu Vs. Union of India and others, and Jasjit Singh and others. The court found that the respondents did not dispute that the petitioner's case was covered by these precedents. Consequently, the impugned notice was quashed. The respondents were granted liberty to proceed against the petitioner in accordance with law. No specific amount in dispute was recorded.

What were the facts?

The petitioner, Sanat Enterprises Private Limited, filed a writ petition before the Punjab and Haryana High Court challenging a notice issued under Section 148 of the Income Tax Act, 1961. The petitioner argued that the notice was invalid as it was issued by the Jurisdictional Assessing Officer, contrary to a notification dated March 29, 2022, which mandated faceless assessments. The petitioner relied on two previous judgments of the same court in support of their contention. The respondents, the Income Tax Department, did not dispute the facts and conceded that the petitioner's case was covered by the aforementioned judgments.

What were the issues?

1. Whether the notice issued under Section 148 of the Income Tax Act, 1961, by the Jurisdictional Assessing Officer is invalid in light of the notification dated March 29, 2022, mandating faceless assessments? (Question of law and fact, concerning Section 148 of the Income Tax Act, 1961). Assessee's contentions: The petitioner argued that the notice was issued by an unauthorized authority (Jurisdictional Assessing Officer) and that the notification dated March 29, 2022, which stipulated faceless assessment, should have been followed. They relied on the judgments in CWP-15745-2024 (Jatinder Singh Bhangu Vs. Union of India and others) and CWP-21509-2023 (Jasjit Singh and others). Revenue's contentions: The respondents conceded that the petitioner's case was covered by the two judgments cited by the petitioner.

Which sections of the Income-tax Act were involved?

Section 148

AI-generated summary — verify with the full judgment below

CWP-18187-

IN THE Sanat Enterpri Assistant Com and others

CORAM : H

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Present : M fo

M

M

fo

DEEPAK SIB

C dated 09.06.20 under Section challenge rais issued by the done because i issued by the notice could ha

2.

In petitioner plac i. CWP India 2025 (O&M) Sr. No.126

E HIGH COURT OF PUNJAB CHANDIGARH

CWP-1818 Date of De

ses Private Limited

Versus mmissioner of Income Tax Circle

HON’BLE MR. JUSTICE DEEPA HON’BLE MS. JUSTICE LAPITA Mr. Nikhil Goyal Advocate or the petitioner. Mr. Yogesh Putney, Senior Stand Mr. Vaibhav Gupta, Jr. Standing C or the Income Tax Department-re *** BAL, J. (Oral)

Challenge made through the ins 025 (Annexure P-4) 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 B AND HARYANA AT H 87-2025 (O&M) ecision : 07.07.2025

…Petitioner

e 1(1), Chandigarh

…Respondents AK SIBAL A BANERJI ding Counsel and Counsel espondents. 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-5), ment of India, the impugned faceless assessment. sion, learned counsel for the o judgments of this Court:- 2024; and VANDANA 2025.07.09 09:36 I attest to the accuracy and integrity of this document

CWP-18187-

ii. CWP other

3.

L that the case o through the af Benches of thi

4.

In Jatinder Sing dated 09.06.20 Officer, is here the petitioner i

5.

T

July 07, 2025 vandana

Whether speak Whether repor 2025 (O&M) P-21509-2023, titled Jasjit Sin rs, decided on 29.07.2024. 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-4), issued by eby quashed with liberty to the r in accordance with law. he petition is allowed in the abov

(DEEPA

J (LAPIT

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king/reasoned :

Yes/No rtable :

Yes/No gh Vs. Union of India and 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 2025.07.09 09:36 I attest to the accuracy and integrity of this document

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