AMRIT DEEP SINGH vs. UNION OF INDIA AND ORS

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CWP/23690/2021HC Punjab & HaryanaPHHC01106148202121 July 2026Bench: JUSTICE (TO BE NOMINATED),MR. JUSTICE ROHIT KAPOOR8 pages
AI SummaryPartly Allowed

What did the High Court hold?

The High Court held that similar writ petitions challenging notices under Section 148 of the Income Tax Act, 1961, have been disposed of by this Court in terms of its order dated April 20, 2026, in CWP-4734-2022 (Ashish Agarwal vs. Union of India and others), which was based on the Supreme Court's judgment in Union of India and others vs. Ashish Agarwal (2023) 1 SCC 617. The Court also noted that another writ petition, CWP-21666-2021 (Pure Milk Products Pvt. Ltd. vs. Union Of India And Others), challenging a notice under Section 148 on similar grounds, had been dismissed. Since the petitioner stated that the prayer in the present petitions was not opposed and the matters involved the same issue, the Court decided to dispose of the writ petition in terms of the order passed in Ashish Agarwal (supra). Pending applications were also to be disposed of accordingly.

What were the facts?

This judgment concerns writ petitions filed by Amrit Deep Singh and others, challenging notices issued under Section 148 of the Income Tax Act, 1961. The petitioner's counsel stated that similar writ petitions challenging notices under Section 148 have been disposed of by this Court in terms of its order dated April 20, 2026, in CWP-4734-2022 (Ashish Agarwal vs. Union of India and others), which relied on a Supreme Court judgment in Union of India and others vs. Ashish Agarwal, (2023) 1 SCC 617. Another writ petition, CWP-21666-2021 (Pure Milk Products Pvt. Ltd. vs. Union Of India And Others), also challenging a notice under Section 148, was dismissed by this Court. The petitioner's counsel indicated that the prayer in the present petitions is not opposed, given the prior orders.

What were the issues?

1. Whether the writ petitions challenging notices issued under Section 148 of the Income Tax Act, 1961, should be disposed of in terms of the Court's previous orders in similar matters, specifically CWP-4734-2022 (Ashish Agarwal vs. Union of India and others) and CWP-21666-2021 (Pure Milk Products Pvt. Ltd. vs. Union Of India And Others)? Assessee's Contention: The petitioner's counsel argued that the present writ petitions raise the same issue as those previously decided by the Court. They relied on the judgment in Ashish Agarwal (supra) and stated that the prayer in the current petitions is not opposed by the revenue. Revenue's Contention: The judgment does not record any specific arguments made by the revenue's counsel on the merits of the case. However, the petitioner's statement that the prayer is not opposed implies a lack of contestation from the revenue's side regarding the disposal of the petitions in line with previous judgments.

Which sections of the Income-tax Act were involved?

Section 148

AI-generated summary — verify with the full judgment below

290

AMRIT DEEP

UNION OF IN

CORAM: H

Present: M

ASHWANI KU 1.

S Income Tax A Coordinate Be titled as ‘Sada relying upon j Ashish Agarw 2.

A Products Pvt. under section Court today, v 3.

L 1 N THE HIGH COURT OF PU AT CHANDIGA

P SINGH

Versus NDIA AND ORS

HON'BLE THE ACTING CHIE HON'BLE MR. JUSTICE ROH

***** Mr. Sunil Kumar Mukhi, Advoca or the petitioner. Mr. Ranvijay Singh, Sr. Standing Mr. Vidul Kapoor, Jr. Standing C or the respondents. ***** UMAR MISHRA, A.C.J. (Oral) Similar writ petitions challengin Act, 1961 (for short ‘the Act’ ench of this Court vide order dat ashiv Capital Services Pvt. Ltd. judgment of the Supreme Court wal, (2023) 1 SCC 617. Another writ petition No.CWP- Ltd. Vs. Union Of India An 148 of the Act, on the specific g vide separate orders. Learned counsel for the petitio

UNJAB & HARYANA ARH

CWP-23690 23690 23690 23690-2021 2021 2021 2021(O&M) (O&M) (O&M) (O&M)

Date of decision: 21.07.20

....Petitione

...Respondents EF JUSTICE HIT KAPOOR ate g Counsel Counsel, ng notice under section 148 of t ’) have been disposed of by t ted 20.04.2026 in CWP-4734-20 d. Vs. Union of India and other t in Union of India and others -21666-2021 titled as ‘Pure M d Others’, challenging the not grounds, has been dismissed by t oner states that in all connect matters on the passed in Ashi 4.

In of orders passe 5.

21.07.2026 Renu Sharma

Whether sp

Whether re 2 e same issue, the writ petitions ish Agarwal (supra). This prayer n that view of the matter, this p ed in Ashish Agarwal (supra). Pending applications, if any, shall

(ASHW

ACT

peaking/reasoned

: Y eportable

: Y

s be disposed of in terms of ord r of the petitioner is not opposed etition stands disposed of in ter l stand disposed of accordingly. WANI KUMAR MISHRA) ING CHIEF JUSTICE ROHIT KAPOOR)

der d. rms RENU SHARMA 2026.07.24 12:08 I attest to the accuracy and integrity of this document AMRIT DEEP

UNION OF IN

CORAM: H

Present: M

ASHWANI KU 1.

S Income Tax A Coordinate Be titled as ‘Sada relying upon j Ashish Agarw 2.

A Products Pvt. under section Court today, v 3.

L 1 N THE HIGH COURT OF PU AT CHANDIGA

P SINGH

Versus NDIA AND ORS

HON'BLE THE ACTING CHIE HON'BLE MR. JUSTICE ROH

***** Mr. Sunil Kumar Mukhi, Advoca or the petitioner. Mr. Ranvijay Singh, Sr. Standing Mr. Vidul Kapoor, Jr. Standing C or the respondents. ***** UMAR MISHRA, A.C.J. (Oral) Similar writ petitions challengin Act, 1961 (for short ‘the Act’ ench of this Court vide order dat ashiv Capital Services Pvt. Ltd. judgment of the Supreme Court wal, (2023) 1 SCC 617. Another writ petition No.CWP- Ltd. Vs. Union Of India An 148 of the Act, on the specific g vide separate orders. Learned counsel for the petitio

UNJAB & HARYANA ARH

CWP-23690 23690 23690 23690-2021 2021 2021 2021(O&M) (O&M) (O&M) (O&M)

Date of decision: 21.07.20

....Petitione

...Respondents EF JUSTICE HIT KAPOOR ate g Counsel Counsel, ng notice under section 148 of t ’) have been disposed of by t ted 20.04.2026 in CWP-4734-20 d. Vs. Union of India and other t in Union of India and others -21666-2021 titled as ‘Pure M d Others’, challenging the not grounds, has been dismissed by t oner states that in all connect matters on the passed in Ashi 4.

In of orders passe 5.

21.07.2026 Renu Sharma

Whether sp

Whether re 2 e same issue, the writ petitions ish Agarwal (supra). This prayer n that view of the matter, this p ed in Ashish Agarwal (supra). Pending applications, if any, shall

(ASHW

ACT

peaking/reasoned

: Y eportable

: Y

s be disposed of in terms of ord r of the petitioner is not opposed etition stands disposed of in ter l stand disposed of accordingly. WANI KUMAR MISHRA) ING CHIEF JUSTICE ROHIT KAPOOR)

der d. rms RENU SHARMA 2026.07.24 12:08 I attest to the accuracy and integrity of this document AMRIT DEEP

UNION OF IN

CORAM: H

Present: M

ASHWANI KU 1.

S Income Tax A Coordinate Be titled as ‘Sada relying upon j Ashish Agarw 2.

A Products Pvt. under section Court today, v 3.

L 1 N THE HIGH COURT OF PU AT CHANDIGA

P SINGH

Versus NDIA AND ORS

HON'BLE THE ACTING CHIE HON'BLE MR. JUSTICE ROH

***** Mr. Sunil Kumar Mukhi, Advoca or the petitioner. Mr. Ranvijay Singh, Sr. Standing Mr. Vidul Kapoor, Jr. Standing C or the respondents. ***** UMAR MISHRA, A.C.J. (Oral) Similar writ petitions challengin Act, 1961 (for short ‘the Act’ ench of this Court vide order dat ashiv Capital Services Pvt. Ltd. judgment of the Supreme Court wal, (2023) 1 SCC 617. Another writ petition No.CWP- Ltd. Vs. Union Of India An 148 of the Act, on the specific g vide separate orders. Learned counsel for the petitio

UNJAB & HARYANA ARH

CWP-23690 23690 23690 23690-2021 2021 2021 2021(O&M) (O&M) (O&M) (O&M)

Date of decision: 21.07.20

....Petitione

...Respondents EF JUSTICE HIT KAPOOR ate g Counsel Counsel, ng notice under section 148 of t ’) have been disposed of by t ted 20.04.2026 in CWP-4734-20 d. Vs. Union of India and other t in Union of India and others -21666-2021 titled as ‘Pure M d Others’, challenging the not grounds, has been dismissed by t oner states that in all connect matters on the passed in Ashi 4.

In of orders passe 5.

21.07.2026 Renu Sharma

Whether sp

Whether re 2 e same issue, the writ petitions ish Agarwal (supra). This prayer n that view of the matter, this p ed in Ashish Agarwal (supra). Pending applications, if any, shall

(ASHW

ACT

peaking/reasoned

: Y eportable

: Y

s be disposed of in terms of ord r of the petitioner is not opposed etition stands disposed of in ter l stand disposed of accordingly. WANI KUMAR MISHRA) ING CHIEF JUSTICE ROHIT KAPOOR)

der d. rms RENU SHARMA 2026.07.24 12:08 I attest to the accuracy and integrity of this document AMRIT DEEP

UNION OF IN

CORAM: H

Present: M

ASHWANI KU 1.

S Income Tax A Coordinate Be titled as ‘Sada relying upon j Ashish Agarw 2.

A Products Pvt. under section Court today, v 3.

L 1 N THE HIGH COURT OF PU AT CHANDIGA

P SINGH

Versus NDIA AND ORS

HON'BLE THE ACTING CHIE HON'BLE MR. JUSTICE ROH

***** Mr. Sunil Kumar Mukhi, Advoca or the petitioner. Mr. Ranvijay Singh, Sr. Standing Mr. Vidul Kapoor, Jr. Standing C or the respondents. ***** UMAR MISHRA, A.C.J. (Oral) Similar writ petitions challengin Act, 1961 (for short ‘the Act’ ench of this Court vide order dat ashiv Capital Services Pvt. Ltd. judgment of the Supreme Court wal, (2023) 1 SCC 617. Another writ petition No.CWP- Ltd. Vs. Union Of India An 148 of the Act, on the specific g vide separate orders. Learned counsel for the petitio

UNJAB & HARYANA ARH

CWP-23690 23690 23690 23690-2021 2021 2021 2021(O&M) (O&M) (O&M) (O&M)

Date of decision: 21.07.20

....Petitione

...Respondents EF JUSTICE HIT KAPOOR ate g Counsel Counsel, ng notice under section 148 of t ’) have been disposed of by t ted 20.04.2026 in CWP-4734-20 d. Vs. Union of India and other t in Union of India and others -21666-2021 titled as ‘Pure M d Others’, challenging the not grounds, has been dismissed by t oner states that in all connect matters on the passed in Ashi 4.

In of orders passe 5.

21.07.2026 Renu Sharma

Whether sp

Whether re 2 e same issue, the writ petitions ish Agarwal (supra). This prayer n that view of the matter, this p ed in Ashish Agarwal (supra). Pending applications, if any, shall

(ASHW

ACT

peaking/reasoned

: Y eportable

: Y

s be disposed of in terms of ord r of the petitioner is not opposed etition stands disposed of in ter l stand disposed of accordingly. WANI KUMAR MISHRA) ING CHIEF JUSTICE ROHIT KAPOOR)

der d. rms RENU SHARMA 2026.07.24 12:08 I attest to the accuracy and integrity of this document

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