Punjab & Haryana High Court Judgments — 2025

The High Court allowed the writ petition, disposing of it in terms of the decisions in Jatinder Singh Bhangu vs. Union of India and Jasjit Singh vs. Union of India. In those cited cases, the Court had held that the scheme of faceless assessment, applicable from the stage of show cause notice under Section 148/148A, was evident from Section 151A and Clause 3(b) of the notification dated 29.03.2022. The Court reasoned that the object of faceless assessment would be defeated if a jurisdictional Assessing Officer issued the show cause notice. While circulars and instructions from the Board are binding on authorities, courts are not bound by them. The mandate of Section 144B, 151A read with the notification dated 29.03.2022 was found to be lucid, and statutory provisions could not be overridden by office memorandums or other instructions. The revenue was granted liberty to follow the procedure laid down under the Act, 1961, and proceed accordingly, if so advised.

The High Court disposed of the writ petition in terms of the judgments in *Jatinder Singh Bhangu vs. Union of India and others* and *Jasjit Singh vs. Union of India and others*. In those judgments, the co-ordinate bench had allowed the writ petitions, holding that the scheme of faceless assessment, as applicable from the stage of show cause notice under Section 148A and 148, mandates that such notices should be issued by the NFAC. The court observed that the mandate of Section 144B and 151A read with the notification dated 29.03.2022 is lucid, and departmental instructions cannot override statutory provisions. The judgments granted liberty to the revenue to follow the procedure laid down under the Act, 1961, and proceed accordingly if so advised. The present petition was disposed of on the same basis, with liberty to the revenue to proceed as advised.

The High Court disposed of the writ petition in terms of the judgments in 'Jatinder Singh Bhangu vs. Union of India and others' and 'Jasjit Singh vs. Union of India and others'. In the 'Jatinder Singh Bhangu' case, the Court had observed that Section 151A of the Act, read with Clause 3(b) of the notification dated 29.03.2022, clearly indicated that the scheme of faceless assessment is applicable from the stage of show cause notice under Section 148. The Court held that the object of faceless assessment would be defeated if a show cause notice under Section 148 were issued by a Jurisdictional Assessing Officer. While acknowledging that circulars and instructions cannot override statutory provisions, the Court found the mandate of Section 144B, 151A, and the notification dated 29.03.2022 to be lucid. Consequently, the writ petition was allowed, granting liberty to the revenue to follow the prescribed procedure under the Act, 1961, and proceed accordingly if so advised. All pending applications were also disposed of.

The High Court disposed of the writ petition in terms of the decisions in Jatinder Singh Bhangu vs. Union of India and others (CWP No. 15745-2024, decided on 19.07.2024) and Jasjit Singh vs. Union of India and others (CWP No. 21509-2023, decided on 29.07.2024). The reasoning in Jatinder Singh Bhangu's case highlighted that Section 151A and Clause 3(b) of the notification dated 29.03.2022, issued under Section 151A, clearly indicate that the scheme of faceless assessment is applicable from the stage of show cause notice under Section 148. The Court found the mandate of Section 144B, 151A, read with the notification, to be lucid, and stated that office memorandums or other instructions cannot override statutory provisions. The Court allowed the writ petitions in those cases, granting liberty to the revenue to follow the prescribed procedure if advised. Consequently, the present writ petition was disposed of on similar terms, with all pending applications also disposed of.

The High Court disposed of the writ petition in terms of the decisions in 'Jatinder Singh Bhangu vs. Union of India' and 'Jasjit Singh vs. Union of India'. These previous judgments had allowed writ petitions on similar grounds, holding that the scheme of faceless assessment, as applicable from the stage of show cause notice under Section 148/148A, was evident from Section 151A and Clause 3(b) of the notification dated 29.03.2022. The Court noted that the mandate of Section 144B, 151A, read with the notification, was lucid, and office memorandums or other instructions could not override statutory provisions. The Court granted liberty to the revenue to follow the procedure laid down under the Act, 1961, and proceed accordingly, if so advised. The operative direction was to dispose of the writ petition in terms of the cited precedents.

The High Court disposed of the writ petition in terms of the decisions in Jatinder Singh Bhangu vs. Union of India and Jasjit Singh vs. Union of India. In Jatinder Singh Bhangu's case, the Court had held that Section 151A of the Act, read with notification dated 29.03.2022, clearly indicates that the scheme of faceless assessment is applicable from the stage of show cause notice under Section 148/148A. The Court found no ambiguity in the statutory provisions and stated that office memorandums or other instructions cannot override these statutory provisions. The Co-ordinate Bench had allowed the writ petitions in those cases, granting liberty to the revenue to follow the prescribed procedure and proceed accordingly if so advised. The present judgment follows this precedent.

The High Court disposed of the writ petition in terms of the decisions in Jatinder Singh Bhangu vs. Union of India and others and Jasjit Singh vs. Union of India and others. In Jatinder Singh Bhangu's case, the Court had held that Section 151A of the Act, read with Clause 3(b) of the notification dated March 29, 2022, clearly indicates that the scheme of faceless assessment is applicable from the stage of show cause notice under Section 148. The Court found the mandate of Section 144B, 151A, and the notification to be lucid, stating that office memorandums or other instructions cannot override statutory provisions. The Court allowed the writ petitions, granting liberty to the revenue to follow the procedure laid down under the Act, 1961, and proceed accordingly if so advised. The present petition was disposed of on these same grounds, and all pending applications were also disposed of accordingly.

The High Court disposed of the writ petition in terms of the decisions in Jatinder Singh Bhangu vs. Union of India and others and Jasjit Singh vs. Union of India and others. In those cited cases, the Court had observed that Section 151A of the Income Tax Act, 1961, and Clause 3(b) of the notification dated March 29, 2022, issued thereunder, clearly indicate that the scheme of faceless assessment is applicable from the stage of show cause notice under Section 148. The Court emphasized that the mandate of Section 144B and 151A, read with the notification, is lucid, and office memorandums or other instructions cannot override statutory provisions. The ratio decidendi is that the faceless assessment scheme, as mandated by statutory provisions and notifications, must be followed, and notices under Section 148 should be issued by the designated authority (NFAC) to avoid defeating the object of faceless assessment. The Court granted liberty to the revenue to follow the procedure as laid down under the Act, 1961, and proceed accordingly if so advised. All pending applications were also disposed of.

The High Court disposed of the writ petition in terms of the decisions in Jatinder Singh Bhangu vs. Union of India and others and Jasjit Singh vs. Union of India and others. In those cited cases, the co-ordinate bench had held that the scheme of faceless assessment, as applicable from the stage of show cause notice under Section 148/148A, is evident from Section 151A and the notification dated March 29, 2022. The court found that Clause 3(b) of the notification clearly applies to notices under Section 148. It was further reasoned that assessment proceedings commence from the issuance of the show cause notice, and allowing jurisdictional Assessing Officers to issue such notices would defeat the object of faceless assessment. The court emphasized that statutory provisions are paramount, and office memorandums or other instructions cannot override them. Consequently, the notices issued by jurisdictional Assessing Officers were deemed invalid. The petitions were allowed with liberty to the revenue to follow the prescribed procedure if advised.

The High Court disposed of the writ petition in terms of the decisions in Jatinder Singh Bhangu vs. Union of India and Jasjit Singh vs. Union of India. In those cases, the co-ordinate bench had held that the scheme of faceless assessment, applicable from the stage of show cause notice under Section 148/148A, mandates that such notices should be issued by the NFAC. The court found that Clause 3(b) of the notification dated March 29, 2022, issued under Section 151A, clearly applies to notices under Section 148. The reasoning was that allowing jurisdictional assessing officers to issue these notices would defeat the object of faceless assessment. The court emphasized that statutory provisions like Section 144B and 151A, read with the relevant notification, are lucid, and departmental circulars or office memorandums cannot override these statutory provisions. The petitions were allowed with liberty to the revenue to follow the prescribed procedure under the Act, 1961, if so advised. All pending applications were also disposed of.

The High Court disposed of the writ petition in terms of the judgments in Jatinder Singh Bhangu's case and Jasjit Singh's case. In those cited cases, the coordinate bench had allowed writ petitions on similar issues, holding that the scheme of faceless assessment, as applicable from the stage of show cause notice under Section 148/148A, was evident from Section 151A and the notification dated 29.03.2022. The court noted that the mandate of Section 144B, 151A, read with the notification, was lucid, and office memorandums or other instructions could not override statutory provisions. The revenue was granted liberty to follow the procedure laid down under the Act, 1961, and proceed accordingly if so advised. The present judgment did not expressly leave any issue undecided.

The High Court disposed of the writ petition in terms of the decisions in Jatinder Singh Bhangu vs. Union of India and others and Jasjit Singh vs. Union of India and others. In Jatinder Singh Bhangu's case, the Court had held that the scheme of faceless assessment, as applicable from the stage of show cause notice under Section 148/148A, is evident from Section 151A and the notification dated 29.03.2022. The Court noted that Clause 3(b) of the notification specifically applies the scheme to notices under Section 148. It was reasoned that allowing jurisdictional assessing officers to issue such notices would defeat the object of faceless assessment. The Court emphasized that statutory provisions are paramount, and office memorandums or instructions cannot override them. The judgments allowed the writ petitions, granting liberty to the revenue to follow the prescribed procedure under the Act if so advised. Consequently, the present writ petition was disposed of on similar terms, and all pending applications were also disposed of.

The High Court disposed of the writ petition in terms of its previous decisions in Jatinder Singh Bhangu vs. Union of India and others and Jasjit Singh vs. Union of India and others. In those cases, the Court had held that the scheme of faceless assessment, as applicable from the stage of show cause notice under Section 148 and 148A, is evident from Section 151A and Clause 3(b) of the notification dated 29.03.2022. The Court emphasized that assessment proceedings commence from the issuance of the show cause notice, and allowing jurisdictional assessing officers to issue such notices would defeat the object of faceless assessment. While circulars and instructions from the Board are binding on authorities, courts are not bound by them. The mandate of Section 144B and 151A, read with the notification dated 29.03.2022, was found to be lucid, with no ambiguity. Therefore, office memorandums or other instructions could not override these statutory provisions. The petitions were allowed with liberty to the revenue to follow the prescribed procedure if so advised. The present petition was disposed of on the same basis.

The High Court disposed of the writ petition in terms of the decisions in Jatinder Singh Bhangu vs. Union of India and Jasjit Singh vs. Union of India. In those cases, the co-ordinate benches had allowed the writ petitions, holding that the scheme of faceless assessment, as applicable from the stage of show cause notice under Section 148A and 148, mandates that such notices should be issued by the NFAC. The court noted that Clause 3(b) of the notification dated March 29, 2022, issued under Section 151A, clearly provides for the applicability of the faceless scheme to notices under Section 148. The reasoning emphasized that the object of faceless assessment would be defeated if the jurisdictional Assessing Officer issued the show cause notice. The court also observed that while circulars and instructions from the Board are binding on authorities, courts are not bound by them, but in this instance, the statutory provisions (Section 144B, 151A read with the notification) were lucid, leaving no ambiguity. The revenue was granted liberty to follow the procedure laid down under the Act, 1961, and proceed accordingly if so advised.

The High Court allowed the writ petition, disposing of it in terms of the judgments in Jatinder Singh Bhangu vs. Union of India and others and Jasjit Singh vs. Union of India and others. The reasoning, as indicated by the reliance on the Jatinder Singh Bhangu case, is that Section 151A of the Income Tax Act, 1961, read with Clause 3(b) of the notification dated March 29, 2022, clearly mandates that the scheme of faceless assessment, including the issuance of show cause notices under Section 148, is applicable to the NFAC. The Court found the statutory provisions lucid and unambiguous, stating that departmental circulars or office memorandums cannot override statutory provisions. The ratio decidendi is that the issuance of a Section 148 notice by a jurisdictional Assessing Officer, when the scheme of faceless assessment under Section 151A and related notifications applies, defeats the object of faceless assessment and is therefore invalid. The operative direction was to grant liberty to the revenue to follow the procedure as laid down under the Act, 1961, and proceed accordingly, if so advised.

The High Court disposed of the writ petition in terms of the judgments in Jatinder Singh Bhangu vs. Union of India and others (CWP No. 15745-2024) and Jasjit Singh vs. Union of India and others (CWP No. 21509-2023), decided on July 19, 2024, and July 29, 2024, respectively. These prior judgments had allowed writ petitions on similar issues, holding that the scheme of faceless assessment, as per Section 151A and notification dated March 29, 2022, applies from the stage of show cause notice under Section 148. The Court noted that while circulars and instructions cannot override statutory provisions, the mandate of Section 144B and 151A read with the notification was lucid. The Court granted liberty to the revenue to follow the procedure laid down under the Act, 1961, and proceed accordingly if so advised. All pending applications were also disposed of.

The High Court held that surtax paid is not deductible and that certain indirect expenses should be included in the closing stock valuation. It also ruled that excise duty should be included in closing stock and that video film production expenses fall under Section 37(3A) with a cap, not Section 37(1).

The High Court noted the submission by the assessee's counsel regarding the low tax effect in both appeals. The Revenue's counsel conceded to this fact and requested permission to withdraw the appeals. Consequently, the High Court dismissed the appeals as withdrawn due to the low tax effect. The court explicitly stated that the questions of law would remain open, meaning this decision does not set a precedent on the merits of any substantive legal issue. Any pending applications were also disposed of.

The High Court disposed of the writ petition in terms of the decisions in Jatinder Singh Bhangu vs. Union of India and others (CWP No. 15745-2024, decided on 19.07.2024) and Jasjit Singh vs. Union of India and others (CWP No. 21509-2023, decided on 29.07.2024). In Jatinder Singh Bhangu's case, the Court had held that the scheme of faceless assessment, as per Section 151A and notification dated 29.03.2022, applies from the stage of show cause notice under Section 148A and Section 148. The Court emphasized that statutory provisions are paramount and cannot be overridden by office memorandums or departmental instructions. The object of faceless assessment would be defeated if jurisdictional assessing officers issued such notices. The Co-ordinate Bench in those cases had allowed the writ petitions, granting liberty to the revenue to follow the prescribed procedure under the Act if advised. The present judgment follows this precedent, with the revenue not disputing the applicability of these judgments.

The High Court upheld the Tribunal's opinion regarding the inclusion of certain indirect expenses in the closing stock. The question raised by the assessee was answered in line with a previous order on similar matters.

The High Court disposed of the writ petition in terms of the decisions in Jatinder Singh Bhangu vs. Union of India and others and Jasjit Singh vs. Union of India and others. In Jatinder Singh Bhangu's case, the Court had held that the scheme of faceless assessment, as applicable from the stage of show cause notice under Section 148/148A, is evident from Section 151A and Clause 3(b) of the notification dated 29.03.2022. The Court emphasized that assessment proceedings commence from the issuance of the show cause notice and that the object of faceless assessment would be defeated if a jurisdictional Assessing Officer issues such a notice. It was further noted that while circulars/instructions are binding on authorities, courts are not bound by them, and statutory provisions prevail. The Court found no ambiguity in the statutory provisions, rendering office memorandums or other instructions issued by the Board or other authorities unreliable if they contradict the statute. The operative direction in the cited cases was to grant liberty to the revenue to follow the prescribed procedure under the Act, 1961, and proceed accordingly if advised.

The High Court disposed of the writ petition in terms of the judgments in Jatinder Singh Bhangu vs. Union of India and others and Jasjit Singh vs. Union of India and others. In those cited cases, the coordinate bench had allowed the writ petitions on similar grounds. The reasoning in Jatinder Singh Bhangu's case highlighted that Section 151A of the Act and the notification dated March 29, 2022, clearly indicate the applicability of the faceless assessment scheme from the stage of show cause notice under Section 148/148A. The court emphasized that the object of faceless assessment would be defeated if the jurisdictional Assessing Officer issued such notices. While circulars and instructions from the Board are binding on authorities, courts are not bound by them, and statutory provisions prevail. The court found no ambiguity in the statutory provisions, rendering departmental instructions or office memorandums relied upon by the revenue as non-binding. The operative direction in the cited cases was to grant liberty to the revenue to follow the procedure as laid down under the Act and proceed accordingly, if so advised.

The High Court, upon agreement of both parties, set aside the impugned order. The matter was remanded back to the Tribunal for passing a fresh order in accordance with law, considering subsequent Supreme Court and Tribunal decisions.

The High Court held that the impugned notice dated 25.06.2025, issued by the Jurisdictional Assessing Officer, was invalid. This decision was based on the law laid down in two previous judgments of the Court, Jatinder Singh Bhangu's case and Jasjit Singh's case. These judgments, it is implied, established that notices under Section 148 should have been issued through the faceless assessment procedure as per the Ministry of Finance notification. The Court quashed the impugned notice. The respondent was granted liberty to proceed against the petitioner in accordance with law. No issue was expressly left undecided. The ratio decidendi is that a notice issued in contravention of mandatory procedural requirements, such as faceless assessment, is liable to be quashed.

The High Court held that the impugned notice dated 27.03.2025, issued by the Jurisdictional Assessing Officer, was invalid. This decision was based on the law laid down in the cases of Jatinder Singh Bhangu and Jasjit Singh, which were relied upon by the petitioner. The Court found that the revenue did not contest the applicability of these precedents. Consequently, the notice was quashed. The respondent was granted liberty to proceed against the petitioner in accordance with the law. No specific amount in dispute was recorded. The Court did not leave any issue undecided.

The High Court held that the issue of disallowance of unreconciled inter-bank/inter-branch entries had been settled in favour of the assessee by a previous ITAT order. Since the Revenue had not appealed that prior decision, the current appeal was allowed.

The High Court held that the transfer of the petitioner's assessment jurisdiction to Panaji, Goa, was justified and in accordance with the CBDT circulars dated 24.08.2009 and 11.02.2013. The court found that the centralization of assessment at Panaji was in terms of these circulars, as a link was established between the undisclosed cash transaction by the petitioner and the related entities whose assessment was being centralized at Goa. The court distinguished the present case from Anuben Lalabhai Bharwad's case and M/s RSG Foods Pvt. Ltd.'s case, where no such link was established. Regarding the argument under Section 158BD of the Act, the court held that while incriminating material against an assessee being assessed by a different officer should generally be forwarded, this principle does not apply when the discovered material is linked to other related entities being assessed elsewhere. In such cases, if the revenue bona fide believes it is administratively convenient and in the public interest, and follows the procedure under Section 127, it can centralize the assessment of all connected persons at one place. The court found no legal weight in the petitioner's argument that the material should have been forwarded to Chandigarh. Consequently, the petition was dismissed.

The High Court noted the submission of the learned counsel for the appellant (revenue) that the tax effect in the appeal was below Rs. 2,00,00,000/-. Consequently, the revenue had instructions to withdraw the appeal in accordance with clause 3.1(f) of Circular No. 5/2024. The revenue also requested that any question of law arising from the appeal be kept open for adjudication in appropriate proceedings. The High Court accepted this submission and accordingly dismissed the appeal as withdrawn. The court explicitly stated that the question of law, as may arise in the appeal, is kept open for adjudication in appropriate proceedings. No decision was made on the merits of the case.

The High Court disposed of the writ petition in terms of the judgments in Jatinder Singh Bhangu vs. Union of India and Jasjit Singh vs. Union of India. In Jatinder Singh Bhangu's case, the Co-ordinate Bench had held that the scheme of faceless assessment, applicable from the stage of show cause notice under Section 148/148A, was evident from Section 151A and Clause 3(b) of the notification dated 29.03.2022. The Court reasoned that the object of faceless assessment would be defeated if a jurisdictional Assessing Officer issued the show cause notice. It was also noted that while circulars and instructions are binding on authorities, courts are not bound by them, and the statutory provisions of Section 144B and 151A, read with the notification, were lucid, leaving no ambiguity. Therefore, office memorandums or other instructions could not override these statutory provisions. The previous judgments had granted liberty to the revenue to follow the prescribed procedure if so advised. The present petition was disposed of on the same basis.

The High Court, following its previous decisions in Jatinder Singh Bhangu vs. Union of India and others and Jasjit Singh vs. Union of India and others, allowed the writ petition. The Court noted that the scheme of faceless assessment, as evident from Section 151A and the notification dated 29.03.2022, applies from the stage of show cause notice under Section 148. The Court reiterated that while circulars and instructions from the Board are binding on authorities, courts are not bound by them if they contradict statutory provisions. The mandate of Section 144B and 151A, read with the notification, was found to be lucid, with no ambiguity. Therefore, any office memorandum or instruction overriding these statutory provisions could not be relied upon. The petition was disposed of in terms of the earlier judgments, granting liberty to the revenue to follow the prescribed procedure if so advised. All pending applications were also disposed of.

The High Court disposed of the writ petition in terms of the judgments in Jatinder Singh Bhangu’s case (decided on 19.07.2024) and Jasjit Singh’s case (decided on 29.07.2024). In Jatinder Singh Bhangu’s case, the Court had held that Section 151A of the Act, read with Clause 3(b) of the notification dated 29.03.2022, clearly indicates that the scheme of faceless assessment is applicable from the stage of show cause notice under Section 148. The Court found the mandate of Section 144B, 151A, and the notification lucid, stating that office memorandums or other instructions cannot override statutory provisions. The Court had allowed the writ petitions in those cases, granting liberty to the revenue to follow the prescribed procedure under the Act if so advised. Consequently, the present writ petition was disposed of on similar terms, implying that the notice issued was indeed without jurisdiction as per the established precedent.

The High Court of Punjab & Haryana, Coram: Hon'ble Mrs. Justice Lisa Gill and Hon'ble Mr. Justice Parmod Goyal, decided to dismiss the appeal as withdrawn. The decision was based on the submission made by the Revenue's counsel, who, on instructions, sought withdrawal of the appeal due to the tax effect being below Rs. 2,00,00,000/-, in accordance with Circular No. 9 of 2024 issued by the CBDT. The Court explicitly noted that the question of law, as may arise in the appeal, would be kept open for adjudication in appropriate proceedings. Therefore, the appeal was disposed of without a decision on the merits of the case, and pending applications were also disposed of.

The High Court disposed of the writ petition in terms of its earlier decisions in Jatinder Singh Bhangu vs. Union of India and others and Jasjit Singh vs. Union of India and others. In those cases, the Court had held that the scheme of faceless assessment, as applicable from the stage of show cause notice under Section 148 and 148A, is evident from Section 151A and the notification dated 29.03.2022. The Court found that the mandate of Section 144B, 151A, read with the notification, is lucid, and any office memorandum or instruction cannot override these statutory provisions. The object of faceless assessment would be defeated if a jurisdictional Assessing Officer issues the show cause notice. The petitions were allowed with liberty to the revenue to follow the prescribed procedure if so advised. The present petition was disposed of on the same basis, and pending applications were also disposed of.

The High Court disposed of the writ petition in terms of the judgments in Jatinder Singh Bhangu vs. Union of India and Jasjit Singh vs. Union of India. In Jatinder Singh Bhangu’s case, the co-ordinate bench had held that the scheme of faceless assessment, applicable from the stage of show cause notice under Section 148, is evident from Section 151A and the notification dated 29.03.2022. The Court noted that the object of faceless assessment would be defeated if a jurisdictional Assessing Officer issued the notice. It was further observed that while circulars and instructions are binding on authorities, courts are not bound by them, and statutory provisions, such as Section 144B and 151A read with the notification, are lucid and unambiguous, overriding any office memorandum or departmental instructions. The petitions were allowed with liberty to the revenue to follow the prescribed procedure if so advised. Consequently, the present writ petition was disposed of on the same basis, and all pending applications were also disposed of.

The High Court disposed of the writ petition in terms of its previous judgments in Jatinder Singh Bhangu vs. Union of India and others and Jasjit Singh vs. Union of India and others. In those prior decisions, the Court had held that the scheme of faceless assessment, as evident from Section 151A and the notification dated 29.03.2022, is applicable from the stage of show cause notice under Section 148/148A. The Court reasoned that the mandate of Section 144B and 151A read with the notification is lucid, and any office memorandum or instruction issued by the Board or any other authority cannot override these statutory provisions. The object of faceless assessment would be defeated if a jurisdictional Assessing Officer issues the show cause notice. Consequently, the writ petitions were allowed, granting liberty to the revenue to follow the prescribed procedure under the Act, 1961, if so advised. The present petition was disposed of on the same basis, and all pending applications were also disposed of.

The High Court disposed of the writ petition in terms of the decisions in Jatinder Singh Bhangu's case and Jasjit Singh's case. In those cited cases, the Court had held that the scheme of faceless assessment, as applicable from the stage of show cause notice under Section 148/148A, is evident from Section 151A and the CBDT notification dated 29.03.2022. The Court noted that Clause 3(b) of the notification clearly applies to notices under Section 148. It was further reasoned that assessment proceedings commence from the issuance of a show cause notice, and allowing a jurisdictional Assessing Officer to issue such a notice would defeat the object of faceless assessment. The Court emphasized that while circulars and instructions from the Board are binding on authorities, courts are not bound by them, and statutory provisions prevail. The judgments in the cited cases allowed the writ petitions, granting liberty to the revenue to follow the prescribed procedure under the Act if so advised. Therefore, the present petition was disposed of on similar lines, implying the notice was likely quashed with liberty to issue a fresh notice in accordance with the law.

The High Court disposed of the writ petition in terms of the judgments in Jatinder Singh Bhangu vs. Union of India and Jasjit Singh vs. Union of India. In those cases, the co-ordinate bench had found that Section 151A of the Income Tax Act, 1961, read with notification dated 29.03.2022, clearly indicated that the scheme of faceless assessment was applicable from the stage of show cause notice under Section 148. The Court held that the object of faceless assessment would be defeated if a jurisdictional Assessing Officer issued such a notice. It was further noted that while circulars and instructions from the Board are binding on authorities, courts are not bound by them, and statutory provisions prevail. The judgments allowed the writ petitions, granting liberty to the revenue to follow the prescribed procedure if advised. The present petition was disposed of on the same basis.

The tribunal held that the expenses incurred for feasibility and expansion activities, even if the project did not materialize, were deductible under Section 35D and Section 37 of the Income Tax Act. The tribunal also found no reason to deny the deduction for warranty claims as they were allowed in subsequent years.

The Tribunal correctly disallowed the guest house expenses based on Section 37(4) of the Income Tax Act, as there is no provision for setting off presumptive receipts against actual expenditure. The issue of interest on interest-free loans to a sister concern was also decided against the assessee based on previous High Court judgments.

The High Court has indicated that the detailed order for this appeal is identical to the one passed in ITA-390-2011. Consequently, the findings, reasoning, and ratio decidendi of the Tribunal for ITA-394-2011 would be the same as those in ITA-390-2011. However, without the detailed order, the specific holdings on any issues, the reasoning process, and the operative directions (such as remand or deletion) cannot be determined from this judgment alone. Any issue expressly left undecided in the referenced detailed order would also remain undecided for this appeal.

The High Court has not provided a decision on the merits of the appeal in this excerpt. Instead, it has stated that 'For orders, see detailed order of even date passed in ITA-390-2011 titled as 'State Bank of Patiala VS Commissioner of Income tax, Patiala.' This indicates that the present appeal's outcome is contingent upon or identical to the decision in the aforementioned related case. Any pending miscellaneous applications are also to be disposed of in accordance with the main order. No specific findings, reasoning, or ratio decidendi are present in this text regarding the issues of the appeal itself.

The Tribunal has not provided a decision on the merits of the appeal in the given text. Instead, it directs that the order for this appeal is to be found in a separate, detailed order of the same date concerning ITA-390-2011. The judgment also states that any pending miscellaneous applications will be disposed of. No specific findings, reasoning, ratio, or operative directions are recorded for this particular appeal within the provided text.

The High Court of Punjab & Haryana at Chandigarh, through its order of even date, has disposed of Income-tax Appeal No. 393-2011. The decision in this appeal is based on the detailed order passed in ITA-390-2011, 'State Bank of Patiala VS Commissioner of Income Tax, Patiala.' Consequently, any pending miscellaneous applications related to this appeal are also disposed of. The specific findings, reasoning, and ratio decidendi from the order in ITA-390-2011 are not provided in this excerpt, nor are the operative directions or any issues left undecided. The judgment does not record any specific findings on the merits of the appeal.

The High Court has held that the present appeal (ITA No. 391-2011) is to be decided based on the detailed order passed on the same date in Income-tax Appeal No. 390-2011, which involves the same appellant and respondent. The Court has directed that for the full reasoning and decision, reference should be made to the detailed order in ITA-390-2011. Any pending miscellaneous applications are also to be disposed of in conjunction with this order. No specific findings or ratio decidendi on any substantive issue are provided in this judgment itself, as it is a procedural order directing reference to another judgment.

The Tribunal has not provided a decision on the merits of the appeal in this excerpt. Instead, it has indicated that the order for this appeal will be based on a detailed order of even date passed in a related matter, ITA-390-2011. Therefore, the specific findings, reasoning, ratio, and operative directions for this particular appeal are not recorded here. Any pending miscellaneous applications are also to be disposed of in line with the main order.

The Tribunal has not provided a decision on the merits of the appeal in this excerpt. Instead, it has stated that "For orders, see detailed order of even date passed in ITA-390-2011 titled as 'State Bank of Patiala VS Commissioner of Income tax, Patiala.'" This indicates that the operative part of the decision in this appeal is contained within the aforementioned related case. Any pending miscellaneous applications are also disposed of as per the order in the related case. No specific findings, reasoning, ratio, or operative directions are discernible from this text for the present appeal.

The High Court held that the Tribunal should have adjudicated the issues even without COD approval, citing a Supreme Court judgment. As the Tribunal had not adjudicated four issues, the High Court decided to remand all appeals back to the Tribunal.

The High Court of Punjab & Haryana at Chandigarh, in its order dated 03.12.2025, has stated that for the present order, reference should be made to a detailed order of even date passed in ITA-390-2011, titled 'State Bank of Patiala VS Commissioner of Income tax, Patiala.' Consequently, the specific findings, reasoning, and ratio decidendi pertaining to Income-tax Appeal No. 432-2015 are not elaborated in this excerpt. The court also directed that any pending miscellaneous applications shall stand disposed of. No specific relief or operative directions are mentioned for this appeal, other than the reference to the other order.

The High Court decided issues related to surtax and inclusion of expenses in closing stock against the assessee. Issues regarding R&D expenses and extra shift allowance were decided in favour of the assessee. The issue of weighted deduction under Section 35B was remanded to the Assessing Officer.

The Tribunal held that property received on partial partition and its accretions continue to belong to the HUF. Consequently, the income flowing therefrom is not includible in the individual assessment of the assessee.