M/S BHANU INFRABUILD PVT LTD vs. DEPUTY COMMISSIONER OF INCOME TAX CENTRAL CIRCLE I AND OTHERS
What did the High Court hold?
The High Court, in light of the consensus between the parties and following its own previous decision in CWP-15791-2024 (Jyoti Sareen vs. Union of India and others) dated 10.09.2026, allowed the petition. The Court quashed the impugned notice dated 30.03.2023 issued to the petitioner under Section 148 of the Income Tax Act, 1961, and any consequential proceedings. The reasoning is based on the agreement of the parties to grant the same relief as in the cited precedent, implying that the facts and legal grounds in the present case were similar enough to warrant identical treatment. The ratio decidendi is that where parties agree to follow a prior judgment on similar facts, the court will grant the same relief.
What were the facts?
The petitioner, Infrabuild Pvt Ltd, filed a writ petition before the High Court of Punjab and Haryana. The petition challenged an action taken by the Deputy Commissioner of Income Tax, Central Circle-I. The specific action under challenge appears to be a notice issued to the petitioner under Section 148 of the Income Tax Act, 1961, along with consequential proceedings. The judgment notes that the parties agreed to the same relief as granted in a previous case, CWP-15791-2024, Jyoti Sareen vs. Union of India and others, decided on 10.09.2026. The notice to the petitioner was dated 30.03.2023.
What were the issues?
1. Whether the impugned notice issued under Section 148 of the Income Tax Act, 1961, and consequential proceedings are liable to be quashed. The assessee (petitioner) likely argued that the notice and proceedings were invalid or not in accordance with the law, seeking relief based on the precedent set in the Jyoti Sareen case. The revenue (respondents) likely contested this, arguing for the validity of the notice and proceedings. The judgment does not explicitly detail the revenue's arguments but implies their opposition to the relief sought by the petitioner. The core of the dispute revolves around the validity of the reassessment proceedings initiated by the notice.
Which sections of the Income-tax Act were involved?
AI-generated summary — verify with the full judgment below
139 139 139 139
IN T IN T IN T IN T
M/S BHANU M/S BHANU M/S BHANU M/S BHANU DEPUTY COM DEPUTY COM DEPUTY COM DEPUTY COM AND OTHER AND OTHER AND OTHER AND OTHER
CORAM: CORAM: CORAM: CORAM: HO HO
HO HO
Present : 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 3 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 AT AT AT CHANDIGARH CHANDIGARH CHANDIGARH CHANDIGARH
CW CW CW CW Da Da Da Da
INFRABUILD PVT LTD INFRABUILD PVT LTD INFRABUILD PVT LTD INFRABUILD PVT LTD
VERSUS VERSUS VERSUS VERSUS MMISSIONER OF INCOME T MMISSIONER OF INCOME T MMISSIONER OF INCOME T MMISSIONER OF INCOME T RS RS RS RS
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. Yuvraj Singh, Advocate and s. Shruti Garg, Advocate, for the r. Ranvijay Singh, Sr. Standing C r. Vidul Kapoor, Jr. Standing Co 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 30.03.2023 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-15773 15773 15773 15773-2025 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 TAX CENTRAL CIRCLE I TAX CENTRAL CIRCLE I TAX CENTRAL CIRCLE I TAX CENTRAL CIRCLE I
...RESPONDENTS ...RESPONDENTS ...RESPONDENTS ...RESPONDENTS PAK SIBAL PAK SIBAL PAK SIBAL PAK SIBAL ISH BINDLISH ISH BINDLISH ISH BINDLISH ISH BINDLISH e petitioner. Counsel with unsel, 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 2026.09.13 11:59 I attest to the accuracy and integrity of this document
More judgments on Section 148
- Bha Associates Pvt. Ltd., New Delhi vs ACIT, Central Circle- 29, New DelhiITA 5208/DEL/2018[2015-16]Status: Disposed6 Nov 2026AY 2015-16
- ACIT Central Bilaspur, Bilaspur vs Arun Kumar Agrawal, SaktiITSSA 26/RPR/2025[2018-19]Status: Disposed21 Oct 2026AY 2018-19
- Vinod Agrawal, Kawardha vs Assisstant Commissioner of Income Tax…ITA 666/RPR/2026[2019-20]Status: Heard21 Oct 2026AY 2019-20
- Sar Business Tradelink Private Limited… vs Income Tax Officer, Ward - 1(2), RaipurITA 599/RPR/2026[2014-15]Status: Heard21 Oct 2026AY 2014-15
- Neo Incorporation, Rajkot vs DCIT Circle- 1(2), RajkotITA 471/RJT/2026[2012-2013]Status: Disposed21 Oct 2026AY 2012-2013
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