FLINT POWER TOOLS PRIVATE LIMITED vs. ASSISTANT COMMISSIONER OF INCOME TAX AND OTHERS

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CWP/11667/2025HC Punjab & HaryanaPHHC01064592202506 May 2025Bench: MRS. JUSTICE LISA GILL,MRS. JUSTICE SUDEEPTI SHARMA1 pages
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What did the High Court hold?

The High Court, in light of the consensus arrived at between the parties and following the precedent set in Jyoti Sareen's case (CWP-15791-2024), allowed the writ petition. The Court quashed the impugned notice dated 22.03.2025 issued to the petitioner under Section 148 of the Income Tax Act, 1961. Consequently, all consequential reassessment proceedings, if any, initiated pursuant to the said notice were also set aside. The reasoning is based on the agreement of the parties to extend the relief granted in the cited judgment to the present petitioner. The ratio decidendi is that where parties agree to follow a prior binding precedent in a similar matter, the court will grant the same relief. No issues were expressly left undecided.

What were the facts?

The case involves a writ petition filed by Flint Power Tools Private Limited (the petitioner) against the Commissioner of Income Tax and others (the respondents). The petitioner sought relief similar to that granted in a previous judgment, CWP-15791-2024, titled Jyoti Sareen vs. Union of India, decided on 10.09.2026. The petitioner's grievance stemmed from a notice dated 22.03.2025 issued under Section 148 of the Income Tax Act, 1961, initiating reassessment proceedings. The High Court considered the arguments presented by both parties and the precedent set in the Jyoti Sareen case. The matter was decided based on a consensus reached between the parties.

What were the issues?

1. Whether the impugned notice dated 22.03.2025 issued under Section 148 of the Income Tax Act, 1961, is liable to be quashed, and consequential reassessment proceedings are to be set aside? (Question of law and fact, turning on Section 148 of the Income Tax Act, 1961). Assessee's Contentions: The assessee argued that they should be entitled to the same relief as granted in the case of Jyoti Sareen vs. Union of India (CWP-15791-2024), which was decided on 10.09.2026. This implies that the grounds for challenging the Section 148 notice in the present case are similar to those in the precedent case. Revenue's Contentions: The judgment records that the parties agreed to the same relief as granted in the Jyoti Sareen case. Therefore, the revenue implicitly consented to the quashing of the impugned notice and consequential proceedings, as per the consensus reached.

Which sections of the Income-tax Act were involved?

Section 148

AI-generated summary — verify with the full judgment below

238 238 238 238

IN T IN T IN T IN T FLINT POWE FLINT POWE FLINT POWE FLINT POWE ASSISTANT ASSISTANT ASSISTANT ASSISTANT

CORAM: CORAM: CORAM: CORAM: HO HO

HO HO

Present : M M M M M for **

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

14.09 14.09 14.09 14.09.2026 .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

ER TOOLS PRIVATE LIMITED ER TOOLS PRIVATE LIMITED ER TOOLS PRIVATE LIMITED ER TOOLS PRIVATE LIMITED VERSUS VERSUS VERSUS VERSUS COMMISSIONER OF INCOM COMMISSIONER OF INCOM COMMISSIONER OF INCOM COMMISSIONER OF INCOM

ON'BLE MR. JUSTICE ON'BLE MR. JUSTICE ON'BLE MR. JUSTICE ON'BLE MR. JUSTICE DEEP DEEP DEEP DEEP ON’BLE MR. JUSTICE SUNI ON’BLE MR. JUSTICE SUNI ON’BLE MR. JUSTICE SUNI ON’BLE MR. JUSTICE SUNI Mr. Nikhil Goyal, Advocate and r. Rana Gurtej Singh, Advocate, r. Varun Issar, Sr. Standing Coun s. Pridhi Sandhu, Advocate and s. Nikita Garg, Jr. Standing Coun r the respondents-Income Tax D *** 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 22.03.2025 issued to the petitio ct, 1961 alongwith consequential

Whether speaking/reasoned. : Ye Whether Reportable. : Ye AB AB AB AB AND HARYANA AND HARYANA AND HARYANA AND HARYANA H WP WP WP WP-11667 11667 11667 11667-2025 2025 2025 2025 ate of Decision : ate of Decision : ate of Decision : ate of Decision : 14.09. 14.09. 14.09. 14.09.2026 2026 2026 2026

...PETITIONER ...PETITIONER ...PETITIONER ...PETITIONER ME TAX AND OTHERS ME TAX AND OTHERS ME TAX AND OTHERS ME TAX AND OTHERS

...RESPONDENTS ...RESPONDENTS ...RESPONDENTS ...RESPONDENTS PAK PAK PAK PAK SIBAL SIBAL SIBAL SIBAL ISH BINDLISH ISH BINDLISH ISH BINDLISH ISH BINDLISH for the petitioner. nsel with

nsel, epartment. 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 2026.09.16 19:55 I attest to the accuracy and integrity of this document

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