M3M INDIA PRIVATE LIMITED vs. DEPUTY COMMISSIONER OF INCOME TAX AND OTHERS

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CWP/24687/2024HC Punjab & HaryanaPHHC01128142202424 September 2024Bench: MR. JUSTICE SANJEEV PRAKASH SHARMA,MR. JUSTICE SANJAY VASHISTH1 pages
AI SummaryPartly Allowed

What did the High Court hold?

The High Court, upon hearing the learned counsel for the parties, noted their agreement that the petitioner should be entitled to the same relief as granted in the judgment dated 10.09.2026 in CWP-15791-2024 – Jyoti Sareen vs. Union of India and others. In light of this consensus, the Court allowed the petition. The operative directions were to quash the impugned notice dated 31.08.2024 issued to the petitioner under Section 148 of the Income Tax Act, 1961, and any consequential proceedings. The reasoning was based on the mutual agreement of the parties to follow the precedent set in the Jyoti Sareen case. The ratio decidendi is that if parties consent to apply the relief granted in a prior, similar judgment, the court will uphold such consent and grant the same relief.

What were the facts?

The petitioner, M3M INDIA HOLDINGS PRIVATE LIMITED, filed a writ petition before the High Court of Punjab and Haryana challenging an action by the Revenue. The specific action under challenge was a notice dated 31.08.2024 issued to the petitioner under Section 148 of the Income Tax Act, 1961, along with consequential proceedings. The assessment year(s) are not explicitly stated. The procedural history indicates that the parties agreed to a consent order. The High Court referred to a previous judgment in Jyoti Sareen vs. Union of India dated 10.09.2026, which dealt with a similar issue.

What were the issues?

1. Whether the impugned notice dated 31.08.2024 issued under Section 148 of the Income Tax Act, 1961, and consequential proceedings are liable to be quashed? (Question of law and mixed fact and law, turning on Section 148). Assessee's Contention: The assessee argued that they should be entitled to the same relief as granted in a previous judgment of the High Court in CWP-15791-2024 – Jyoti Sareen vs. Union of India and others. This implies the assessee believed their case was factually and legally similar to the Jyoti Sareen case and thus merited the same outcome. Revenue's Contention: The Revenue, represented by learned Senior Standing Counsel and Junior Standing Counsel, agreed with the assessee's submission that the petitioner should be entitled to the same relief as granted in the Jyoti Sareen case. This indicates the Revenue did not contest the assessee's claim for similar relief.

Which sections of the Income-tax Act were involved?

Section 148

AI-generated summary — verify with the full judgment below

247 247 247 247

IN T IN T IN T IN T M3M INDIA H M3M INDIA H M3M INDIA H M3M INDIA H DEPUTY COM DEPUTY COM DEPUTY COM DEPUTY COM

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 3 Income Tax Ac

10.09 10.09 10.09 10.09.2026 .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

HOLDINGS PRIVATE LIMIT HOLDINGS PRIVATE LIMIT HOLDINGS PRIVATE LIMIT HOLDINGS PRIVATE LIMIT VERSUS VERSUS VERSUS VERSUS MMISSIONER OF INCOME T MMISSIONER OF INCOME T MMISSIONER OF INCOME T MMISSIONER OF INCOME T

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, for th Ms. Urvashi Dhugga, Sr. Standing r. Vaibhav Gupta, Jr. Standing C s. Kavita, Advocate and s. Arushi Bansal, Advocate r the respondents. *** 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 31.08.2024 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-24687 24687 24687 24687-2024 2024 2024 2024 ate of Decision : ate of Decision : ate of Decision : ate of Decision : 10.09. 10.09. 10.09. 10.09.2026 2026 2026 2026

ED ED ED ED ...PETITIONER ...PETITIONER ...PETITIONER ...PETITIONER TAX AND OTHERS TAX AND OTHERS TAX AND OTHERS TAX AND OTHERS

...RESPONDENTS ...RESPONDENTS ...RESPONDENTS ...RESPONDENTS PAK SIBAL PAK SIBAL PAK SIBAL PAK SIBAL ISH BINDLISH ISH BINDLISH ISH BINDLISH ISH BINDLISH he petitioner. g Counsel with Counsel 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 2026.09.15 11:25 I attest to the accuracy and integrity of this document

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