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The High Court held that the impugned notice dated 30.03.2025, issued by the Jurisdictional Assessing Officer, was invalid. The Court found that the respondent did not dispute the petitioner's contention that the case was covered by the judgments in Jatinder Singh Bhangu and Jasjit Singh. In light of these precedents, which established that notices under Section 148 should be issued through faceless assessment as per the notification, the Court quashed the impugned notice. The respondents were granted liberty to proceed against the petitioner in accordance with the law. The ratio decidendi is that a notice issued by a Jurisdictional Assessing Officer under Section 148, when the applicable notification mandates faceless assessment, is liable to be quashed.
The High Court noted that a co-ordinate bench had previously decided the same issue in Jatinder Singh Bhangu's case and Jasjit Singh's case, allowing the writ petitions. In those cases, the court held that the scheme of faceless assessment, as per Section 151A and the notification dated 29.03.2022, applies from the stage of the show cause notice under Section 148. The court emphasized that the mandate of Section 144B and 151A read with the notification is lucid, and departmental instructions cannot override statutory provisions. Consequently, the present writ petition was disposed of with a direction to the Appellate Authority to decide the pending appeal in terms of the aforementioned judgments.
The High Court noted that a co-ordinate bench in Jatinder Singh Bhangu's case and Jasjit Singh's case had allowed writ petitions on the same issue. In Jatinder Singh Bhangu's case, the Court had observed that Section 151A and Clause 3(b) of the notification dated 29.03.2022 clearly indicate 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 jurisdictional assessing officer issued such notices. While acknowledging that circulars and instructions cannot override statutory provisions, the Court found the mandate of Section 144B, 151A, read with the notification, to be lucid. Consequently, the High Court disposed of the present writ petition with a direction to the Appellate Authority to decide the pending appeal in terms of the aforementioned judgments, granting liberty to the revenue to follow the procedure laid down under the Act, 1961, and proceed accordingly if so advised.
The High Court noted that a co-ordinate bench had previously allowed writ petitions on the same issue in Jatinder Singh Bhangu's case and Jasjit Singh's case. In those cases, the court had held that Section 151A of the Act, read with the notification dated 29.03.2022, clearly indicates that the scheme of faceless assessment applies from the stage of show cause notice under Section 148. The court emphasized that the object of faceless assessment would be defeated if a Jurisdictional Assessing Officer issued such notices. While circulars and instructions cannot override statutory provisions, the mandate of Section 144B and 151A was lucid. The High Court, in the present case, disposed of the writ petition with a direction to the Appellate Authority to decide the pending appeal in terms of the aforementioned judgments, which had granted liberty to the revenue to follow the prescribed procedure if so advised.
The High Court held that the appeal should be dismissed as withdrawn. The reasoning was based on the submission made by the learned counsel for the appellant (Revenue) that the tax effect involved in the appeal was below the threshold stipulated in Circular No. 9 of 2024 dated 17.09.2024, which mandated withdrawal of appeals with such tax effects. Therefore, the appeal was accordingly dismissed as withdrawn. Any pending applications were also disposed of.
The High Court allowed the application to withdraw the appeal as the assessee had opted for the Vivad Se Vishwas Scheme. Liberty was granted to the appellant to file an appropriate application if the assessee violated the scheme's conditions.
The High Court allowed the application for withdrawal of the appeal. The appeal was dismissed as withdrawn, with liberty granted to the appellant to file appropriate applications if the assessee violated the scheme's conditions.
The High Court allowed the application for withdrawal of the appeal. The questions of law were kept open for future adjudication, and liberty was granted to file an application if the assessee violated the scheme's conditions.
The High Court allowed the application for withdrawal of the appeal. The appeal was dismissed as withdrawn, with liberty granted to the appellant to take appropriate action if the assessee violated the scheme's conditions.
The High Court allowed the appellant's request to withdraw the appeal as the assessee had opted for the Vivad Se Vishwas Scheme. Liberty was granted to the appellant to file appropriate applications if the scheme conditions were violated.
The High Court of Punjab & Haryana at Chandigarh dismissed the writ petition as withdrawn. The Court granted liberty to the petitioner to pursue his remedy before the correct jurisdictional court. This decision was based on the respondent's submission that the petitioner's PAN was registered in Bihar and the notice under Section 148 of the Income Tax Act was issued by the Income Tax Officer in Muzaffarpur, Bihar, indicating that the Punjab & Haryana High Court was not the appropriate forum. No decision was made on the merits of the case.
The High Court of Punjab and Haryana at Chandigarh dismissed the appeal as withdrawn. The decision was based on the submission made by the learned counsel for the appellant (revenue) that the tax effect involved in the appeal was below the threshold stipulated in CBDT Circular No. 9 of 2024, which provided for withdrawal of appeals. Consequently, the revenue had instructions to withdraw the appeal. The court found no reason to proceed with the merits of the case and disposed of the appeal accordingly. Any pending applications were also disposed of.
The High Court allowed the application for withdrawal of the appeal. The appeal was dismissed as withdrawn, with liberty granted to the appellant to file an appropriate application if the assessee violated the scheme's conditions.
The High Court allowed the application for withdrawal of the appeal. The appeal was dismissed as withdrawn, with liberty granted to the appellant to file appropriate applications if the assessee violated the scheme's conditions.
The appeal was dismissed as withdrawn because the assessee had opted for the Vivad Se Vishwas Scheme. Liberty was granted to the appellant to file an appropriate application if the assessee furnished incorrect declarations or violated scheme conditions.
The tribunal allowed the application for withdrawal of the appeal. The appeal was dismissed as withdrawn with liberty to the appellant to file appropriate applications if the assessee violated the scheme's conditions.
The High Court allowed the application for withdrawal of the appeal. The appeal was dismissed as withdrawn, with liberty granted to the appellant to file appropriate applications if the assessee furnished incorrect declarations or violated scheme conditions.
The High Court allowed the application for withdrawal of the appeal. The appeal was dismissed as withdrawn, with liberty granted to the appellant to take appropriate action if the scheme conditions were violated.
The High Court held that the appeal should be dismissed as withdrawn. The reasoning was based on the submission made by the learned counsel for the appellant (Principal Commissioner of Income Tax) that the tax effect involved in the appeal was under Rs. 2 crores. Consequently, in line with specific instructions received pursuant to circular No. 9 of 2024 dated 17.09.2024 issued by the Ministry of Finance, Department of Revenue, CBDT, Government of India, the appellant wished to withdraw the appeal. The Tribunal did not decide the substantive issues of the original appeal.
The High Court allowed the withdrawal of the appeal. The court noted that the new circular aimed to manage litigation and that the present case did not fall under any exceptions to the revised monetary limits.
The tribunal allowed the prayer for withdrawal of the appeal. The appeal was dismissed as withdrawn in light of the revised monetary limits and the appellant's submission that the case did not fall within any exception clauses.
The High Court allowed the application to withdraw the appeal. The appeal was dismissed as withdrawn, with liberty granted to the appellant to file appropriate applications if the assessee violated the scheme's conditions.
The High Court allowed the application for withdrawal of the appeal. The appeal was dismissed as withdrawn, with liberty granted to the appellant to file appropriate applications if the assessee furnished incorrect declarations or violated scheme conditions.
The High Court allowed the application for withdrawal of the appeal. The appeal was dismissed as withdrawn, with liberty granted to the appellant to file appropriate applications if the assessee violated the scheme's conditions.
The High Court allowed the appeal to be withdrawn based on a CBDT circular regarding low tax effect appeals. The appeal was accordingly dismissed as withdrawn.
The High Court allowed the writ petition, disposing of it with a direction to the revenue to follow the procedure laid down in the Act. The Court relied on the decisions of a Co-ordinate Bench in Jatinder Singh Bhangu vs. Union of India and Jasjit Singh vs. Union of India. The Court noted that Section 151A of the Act, read with 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 148A. The Court reiterated the settled proposition of law that assessment proceedings commence from the issuance of the show cause notice and that the object of faceless assessment would be defeated if a show cause notice under Section 148 is issued by the Jurisdictional Assessing Officer. The Court emphasized that circulars, office memorandums, and letters issued by the Board or any other authority cannot override statutory provisions, and courts are bound by the language of statutory provisions. The Court directed that the present writ petition be disposed of in terms of the aforementioned judgments.
The High Court noted that a Co-ordinate Bench had previously allowed writ petitions on the same issue in Jatinder Singh Bhangu's case and Jasjit Singh's case. In those cases, the Court had held that the scheme of faceless assessment, as per Section 151A and the notification dated 29.03.2022, applies from the stage of the show cause notice under Section 148. The Court found no ambiguity in the statutory provisions and observed that departmental circulars or instructions cannot override statutory provisions. The High Court, in the present case, disposed of the writ petition with a direction to the Appellate Authority to decide the pending appeal in terms of the aforementioned judgments, allowing the revenue liberty to follow the prescribed procedure if so advised. The specific finding on the jurisdictional issue was implicitly affirmed by directing the appeal to be decided in line with prior judgments that had found such notices to be without jurisdiction.
The High Court, while acknowledging that an appeal was pending before the Appellate Authority, disposed of the writ petition with a direction to the Appellate Authority. The Appellate Authority was instructed to decide the pending appeal in terms of the judgments previously delivered by a Co-ordinate Bench of the High Court in Jatinder Singh Bhangu's case (decided on 19.07.2024) and Jasjit Singh's case (decided on 29.07.2024). These prior judgments had allowed writ petitions on similar issues, granting liberty to the revenue to follow the prescribed procedure under the Act, 1961. The reasoning in Jatinder Singh Bhangu's case highlighted that Section 151A and the notification dated 29.03.2022 clearly indicate the applicability of the faceless assessment scheme from the stage of show cause notice under Section 148, and that departmental instructions cannot override statutory provisions.
The High Court allowed the writ petition, disposing of it with a direction to the revenue to follow the procedure laid down under the Income Tax Act, 1961, and proceed accordingly, if so advised. The Court relied on the judgments of a Co-ordinate Bench in Jatinder Singh Bhangu's case (supra) and Jasjit Singh's case (supra), decided on 19.07.2024 and 29.07.2024 respectively. The Court noted that Section 151A of the Act, read with 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 148A and notice under Section 148. The Court reiterated the settled proposition of law that assessment proceedings commence from the issuance of the show cause notice and that the introduction of faceless assessment would be defeated if the show cause notice under Section 148 is issued by a Jurisdictional Assessing Officer. The Court emphasized that circulars, office memorandums, and letters issued by the Board or other authorities cannot override statutory provisions, and the language of Section 144B and 151A, read with the notification, is lucid. Therefore, the issuance of the notice by an authority other than the NFAC was found to be without jurisdiction.
The High Court held that the impugned notice dated 17.06.2025, issued by the Jurisdictional Assessing Officer, was invalid. This decision was based on the law laid down in two previous judgments of the same court: CWP No.15745 of 2024 (Jatinder Singh Bhangu Vs. Union of India and others) and CWP No.21509 of 2023 (Jasjit Singh Vs. Union of India and others). The revenue's counsel did not dispute that the petitioner's case was covered by these precedents. Consequently, the notice was quashed. The court granted liberty to the respondents to proceed against the petitioner in accordance with law. No other issues were expressly left undecided.
The High Court held that the impugned notice dated 13.06.2025, issued by the Jurisdictional Assessing Officer under Section 148 of the Income Tax Act, 1961, was liable to be quashed. This decision was based on the law laid down in two previous judgments of the same court in Jatinder Singh Bhangu's case and Jasjit Singh's case. The court found that the respondents did not dispute that these judgments applied to the present case. Consequently, the notice was quashed with liberty granted to the respondents 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 of Punjab & Haryana at Chandigarh, comprising Hon'ble Mrs. Justice Lisa Gill and Hon'ble Mrs. Justice Meenakshi I. Mehta, considered the submissions of both parties. The Court noted that the assessee had instructed its counsel to withdraw the appeal due to a settlement under the Direct Tax Vivad Se Vishwas Scheme, 2024. The revenue's counsel confirmed this settlement and the issuance of Form-4. Consequently, the Court found no impediment to allowing the withdrawal. The appeal was accordingly dismissed as withdrawn. No specific findings on the merits of the original dispute were made, as the appeal was disposed of on a procedural ground arising from the settlement scheme.
The Tribunal noted that the learned counsel for the appellant submitted that the matter has been settled with the Department under the Direct Tax Vivad Se Vishwas Scheme, 2024, and consequently, he had instructions to withdraw the appeal. The learned counsel for the respondent affirmed this settlement and stated that Form-4 had been issued to the appellant. Based on these submissions, the High Court dismissed the appeal as withdrawn. No decision on the merits of the original dispute was made, as the appeal was disposed of due to the settlement under the Vivad Se Vishwas Scheme.
The High Court held that the impugned notices issued under Sections 142 and 148 of the Income Tax Act, 1961, are not liable to be quashed. The Court reasoned that the order dated 04.01.2017, transferring the petitioner's case to Central Circle-2, Chandigarh, was an independent administrative action taken in exercise of administrative exigency under Section 127(2)(a) of the Act, and not a direct consequence of the search and seizure operations. Since this order was not challenged by the petitioner and was not shown to be a direct consequence of the quashed search and seizure, the issuance of notices by the transferred authority cannot be invalidated. The Court distinguished the present case from precedents like Coal India Ltd. and Commissioner of Income Tax-I, Nagpur Vs. Lalitkumar Bardia, where the foundation was indeed knocked off or the transfer order itself was quashed. The principle that 'once foundation is knocked off, the superstructure must fall' was held to have no application here. The Court observed that while the earlier judgment quashed the search and seizure, it did not invalidate independent administrative actions. Consequently, the transfer of jurisdiction was not invalidated by the quashing of the search and seizure operation. The Court also noted that assessment orders have been passed during the pendency of these petitions and granted the petitioner an opportunity to challenge them on merits without delay objections.
The High Court allowed the writ petition, setting aside the notice dated 28.08.2025 issued under Section 148 of the Income Tax Act, 1961, for Assessment Year 2022-2023. The Court relied on its previous decisions in Jatinder Singh Bhangu vs. Union of India and others and Jasjit Singh vs. Union of India and others. The reasoning was that the scheme of faceless assessment, as applicable from the stage of show cause notice under Section 148A and 148, and as clarified by Clause 3(b) of the notification dated 29.03.2022 issued under Section 151A, mandates that such notices should be issued by the National Faceless Assessment Centre (NFAC). The Court noted that allowing the jurisdictional Assessing Officer to issue such notices would defeat the object of faceless assessment. The Court also acknowledged 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 clear. The revenue was granted liberty to follow the procedure laid down under the Act, 1961, and proceed accordingly if so advised. No issue was expressly left undecided.
The High Court allowed the writ petition, setting aside the notice and assessment order. The Court relied on its previous decisions in Jatinder Singh Bhangu and Jasjit Singh, which held that the scheme of faceless assessment, applicable from the stage of show cause notice under Section 148, mandates that such notices be issued by the National Faceless Assessment Centre (NFAC) as per Section 151A and the notification dated March 29, 2022. The Court noted that while circulars and office memorandums cannot override statutory provisions, the mandate of Section 144B and 151A read with the notification is clear. The Court granted liberty to the revenue to follow the prescribed procedure under the Act if so advised. The appeal pending before the Appellate Authority was directed to be decided in terms of these judgments.
The High Court allowed the writ petition, disposing of it in terms of the judgments in Jatinder Singh Bhangu vs. Union of India and Jasjit Singh vs. Union of India. These previous judgments 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 of the Act 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 issues such notices. 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 cannot 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 allowed the writ petition, disposing of it in terms of the judgments in Jatinder Singh Bhangu's case and Jasjit Singh's case. The Court noted that a Co-ordinate Bench had previously allowed writ petitions on the same issue, granting liberty to the revenue to follow the procedure laid down under the Act, 1961, and proceed accordingly if so advised. The reasoning in Jatinder Singh Bhangu's case highlighted that Section 151A 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. The Court emphasized that the object of faceless assessment would be defeated if the jurisdictional Assessing Officer issued such notices. It was also stated that while circulars and instructions are binding on authorities, courts are not bound by them, and the mandate of statutory provisions like Section 144B and 151A, read with the notification, is lucid and unambiguous.
The High Court allowed the writ petition, disposing of it in terms of the judgments in Jatinder Singh Bhangu's case and Jasjit Singh's case. The reasoning was that a co-ordinate bench of the High Court had previously allowed writ petitions on the same issue. In Jatinder Singh Bhangu's case, the court observed that Section 151A of the Act, along with the notification dated 29.03.2022, clearly indicates that the scheme of faceless assessment is applicable from the stage of the show cause notice under Section 148 and 148A. The court held that the mandate of Section 144B and 151A read with the notification is lucid, and departmental instructions cannot 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. No issue was expressly left undecided.
The High Court allowed the writ petition, setting aside the notice dated August 28, 2024, issued under Section 148 of the Income Tax Act, 1961, for Assessment Year 2018-2019. The Court relied on its previous decisions in Jatinder Singh Bhangu vs. Union of India and Jasjit Singh vs. Union of India. The reasoning was that the CBDT circular dated March 29, 2022, read with Section 151A of the Act, clearly indicates that the scheme of faceless assessment, including the issuance of notices under Section 148, is to be handled by the National Faceless Assessment Centre (NFAC). The Court found that the issuance of such a notice by the jurisdictional Assessing Officer was contrary to the statutory scheme. The revenue was granted liberty to follow the procedure laid down under the Act, 1961, and proceed accordingly if so advised. No issue was expressly left undecided.
The High Court, while acknowledging that an appeal was pending before the Appellate Authority, disposed of the writ petition. The Court directed the Appellate Authority to decide the pending appeal in terms of the judgments passed by a Co-ordinate Bench in Jatinder Singh Bhangu's case (decided on July 19, 2024) and Jasjit Singh's case (decided on July 29, 2024). These prior judgments 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 148A and 148, mandates the NFAC to issue such notices. The Court noted that while circulars/instructions cannot override statutory provisions, the mandate of Section 144B and 151A read with the notification dated March 29, 2022, was lucid, and the object of faceless assessment would be defeated if the jurisdictional Assessing Officer issued the notice. The revenue was granted liberty to follow the procedure laid down under the Act, 1961, if so advised.
The High Court allowed the writ petition, disposing of it in terms of the judgments in Jatinder Singh Bhangu's case and Jasjit Singh's case. The reasoning was based on the established principle that the scheme of faceless assessment, as applicable from the stage of show cause notice under Section 148 or 148A, is governed by Section 151A of the Act, 1961, and the notification dated 29.03.2022. The Court noted that Clause 3(b) of the notification clearly applies the scheme to notices under Section 148. It was held 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 reiterated that while circulars and instructions are binding on authorities, courts are not bound by them, and the mandate of Section 144B, 151A, read with the notification, is lucid. The operative direction was to grant liberty to the revenue 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 Jasjit Singh vs. Union of India. These prior judgments 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 and 148A, is evident from Section 151A and the CBDT notification dated March 29, 2022. The Court found that the mandate of Section 144B, 151A, read with the notification, was lucid, and statutory provisions cannot 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. No issue was expressly left undecided.
The High Court noted that the appellant's counsel had specific instructions to withdraw the appeal. This instruction was based on the tax effect being under Rs.2 crores and in view of Circular No. 9 of 2024 dated 17.09.2024 issued by the Ministry of Finance, Department of Revenue, CBDT. Consequently, the appeal was dismissed as withdrawn. The operative direction was to dismiss the appeal as withdrawn. No specific issue on the merits of the case was decided, as the appeal was withdrawn before any substantive adjudication.
The High Court allowed the writ petition, setting aside the notice dated 20.06.2025 under Section 148, the notice dated 23.03.2025 under Section 148A(1), and the assessment order dated 20.06.2025 for Assessment Year 2021-2022. The Court followed its previous decisions in Jatinder Singh Bhangu's case and Jasjit Singh's case. The reasoning was 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 applies from the stage of show cause notice under Section 148 and 148A. The Court emphasized that the object of faceless assessment would be defeated if a jurisdictional Assessing Officer issues such notices. It was also noted that departmental circulars or office memorandums cannot override statutory provisions. The revenue was granted liberty to follow the procedure laid down under the Act, 1961, and proceed accordingly if so advised. No issue was expressly left undecided.
The High Court held that the petitioner would be entitled to the same relief as granted in the case of Jyoti Sareen (supra). Consequently, the petition was allowed, and the impugned notice dated 28.03.2024 issued to the petitioner under Section 148 of the Income Tax Act, 1961, along with any consequential proceedings, were quashed. The reasoning was based on the consensus reached between the learned counsel for the parties. The ratio decidendi is that if parties agree to a prior judgment's applicability and relief, the court will grant the same relief. Any pending miscellaneous applications were also disposed of.
The High Court allowed the writ petition, disposing of it in terms of the judgments in Jatinder Singh Bhangu vs. Union of India and Jasjit Singh vs. Union of India. The reasoning was based on the principle 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, not the Jurisdictional Assessing Officer. The Court noted that while circulars/instructions from the CBDT cannot override statutory provisions, the mandate of Section 144B, 151A, read with the notification dated 29.03.2022, was clear. The operative direction was to grant liberty to the revenue to follow the procedure laid down under the Act, 1961, and proceed accordingly, if so advised. No issue was expressly left undecided.
The High Court allowed the writ petition, setting aside the notice and assessment order. The Court followed its previous decisions in Jatinder Singh Bhangu vs. Union of India and Jasjit Singh vs. Union of India. The reasoning was based on Section 151A of the Act and Notification dated 29.03.2022, which indicate that the faceless assessment scheme applies from the stage of show cause notice under Section 148. The Court held that the mandate of Section 144B, 151A, read with the notification, is lucid, and the scheme of faceless assessment would be defeated if a jurisdictional Assessing Officer issues the notice. The Court noted that while circulars are binding on authorities, courts are not bound by them, but in this case, the statutory provisions themselves supported the petitioner's argument. The appeal pending before the Appellate Authority was directed to be decided in terms of the aforementioned judgments. The operative direction was to set aside the impugned notice and assessment order and to have the pending appeal decided by the Appellate Authority.
The High Court noted that the learned counsel for the appellant had instructions to withdraw the appeal. The withdrawal was sought due to a jurisdictional issue, as the order being challenged was passed by the Commissioner of Income Tax (Appeals)-4, Mumbai, and not by the ITAT as initially stated. The Court allowed the withdrawal of the appeal. The judgment explicitly stated that there was no expression of opinion on the merits of the matter or the aspect of delay in filing/re-filing the appeal. The appellant was granted liberty to avail the remedy available in accordance with law before the correct jurisdictional Court. Pending applications were also disposed of.
The Punjab and Haryana High Court at Chandigarh decided to dismiss the appeal as withdrawn. The reasoning provided is that the learned counsel for the appellant (Commissioner of Income Tax) had specific instructions to withdraw the appeal due to the tax effect being under Rs.2 crores, in accordance with Circular No.9 of 2024 dated 17.09.2024 issued by the Ministry of Finance, Department of Revenue, CBDT, Government of India. The operative direction was to dismiss the appeal. No issues were expressly left undecided, as the appeal was disposed of on a procedural ground.