JASWINDER SINGH vs. INCOME TAX OFFICER

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CWP/21419/2025HC Punjab & HaryanaPHHC01117332202529 July 2025Bench: MR. JUSTICE DEEPAK SIBAL,MS. JUSTICE LAPITA BANERJI2 pages
AI SummaryAllowed

What did the High Court hold?

The High Court allowed the petition. It held that the impugned notice dated 22.04.2024, issued by the Jurisdictional Assessing Officer, was liable to be quashed in terms of the law laid down in the High Court's previous judgments in *Jatinder Singh Bhangu Vs. Union of India* and *Jasjit Singh Vs. Union of India*. The reasoning was that the notice was not issued in the prescribed manner of faceless assessment as required by the notification dated 29.03.2022. The court quashed the notice with liberty to the respondents to proceed against the petitioner in accordance with law. No other issue was expressly left undecided.

What were the facts?

The petitioner, Jaswinder Singh, challenged a notice dated 22.04.2024 issued by the Jurisdictional Assessing Officer under Section 148 of the Income Tax Act, 1961. The primary contention was that the notice was invalid because it was not issued in the prescribed manner of faceless assessment, as mandated by a notification dated 29.03.2022 from the Ministry of Finance, Government of India. The petitioner relied on two previous judgments of the High Court of Punjab and Haryana in support of this argument. The respondent, Income Tax Officer, Ward-1, Punjab, 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, is invalid for not being issued in the prescribed manner of faceless assessment, contrary to the notification dated 29.03.2022 issued by the Ministry of Finance. Assessee's contention: The notice is invalid as it was not issued through the faceless assessment procedure, which is mandatory as per the notification dated 29.03.2022. The assessee relies on the High Court's decisions in *Jatinder Singh Bhangu Vs. Union of India* (2024) and *Jasjit Singh Vs. Union of India* (2024). Revenue's contention: The revenue does not dispute the facts and concedes that the petitioner's case is covered by the aforesaid judgments of the High Court.

Which sections of the Income-tax Act were involved?

Section 148

AI-generated summary — verify with the full judgment below

CWP-21419-2

IN THE Jaswinder Sing Income Tax O

CORAM : H

Present : M

M fo (t

DEEPAK SIB

C dated 22.04.20 under Section challenge rais issued by the done because Ministry of Fin been issued on 2.

In petitioner plac i. CWP India ii. CWP other 2025 (O&M) Sr. No.157

E HIGH COURT OF PUNJAB CHANDIGARH

CWP-2141 Date of De

Versus fficer, Ward-1, Punjab

HON’BLE MR. JUSTICE DEEPA HON’BLE MS. JUSTICE LAPITA Mr. Iqbal Roshan, Advocate, or the petitioner. Mr. Ranvijay Singh, Advocate, or the respondent. through video conferencing) *** BAL, J. (Oral)

Challenge made through the ins 024 (Annexure P-1) issued to the 148 of the Income Tax Act, 1 ed by the petitioner is that th Jurisdictional Assessing Office in terms of the notification dat nance, Government of India, the nly by way of faceless assessmen 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 P-21509-2023, titled Jasjit Sin rs, decided on 29.07.2024. Page 1 of 2 B AND HARYANA AT H 19-2025 (O&M) ecision : 29.07.2025

…Petitioner

…Respondent AK SIBAL A BANERJI

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 ted 29.03.2022, issued by the e impugned notice could have nt. sion, learned counsel for the o judgments of this Court:- Singh Bhangu Vs. Union of 2024; and gh Vs. Union of India and VANDANA 2025.08.02 12:23 I attest to the accuracy and integrity of this document

CWP-21419-2

L that the case o through the af Benches of thi 4.

In Jatinder Sing dated 22.04.20 Officer, is here the petitioner i 5.

July 29, 2025 vandana

Whether speak Whether repor 2025 (O&M) 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 ( 024 (Annexure P-1), issued by eby quashed with liberty to the r in accordance with law. he petition is allowed in the abov

(DEEPA

J (LAPIT

king/reasoned :

Yes/No rtable :

Yes/No Page 2 of 2 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 Jurisdictional Assessing respondents to proceed against ve terms. AK SIBAL) JUDGE

TA BANERJI) JUDGE VANDANA 2025.08.02 12:23 I attest to the accuracy and integrity of this document

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