Punjab & Haryana High Court Judgments — 2025

The High Court held that the case of the petitioner was covered by the law laid down in the two judgments previously rendered by co-ordinate Benches of the Court, namely Jatinder Singh Bhangu Vs. Union of India and others and Jasjit Singh Vs. Union of India and others. Consequently, the impugned notice issued under Section 148 of the Income Tax Act, 1961, by the Jurisdictional Assessing Officer, was quashed. The Court granted liberty to the respondents to proceed against the petitioner in accordance with law. No specific issue was left undecided.

The High Court held that the impugned notice dated 23.06.2025, 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 noted that the respondents did not dispute that these judgments covered the petitioner's case. Consequently, the notice was quashed. The respondents were granted liberty to proceed against the petitioner in accordance with the law. The Court did not leave any issue undecided.

The High Court allowed the writ petition, disposing of it in terms of its previous judgments in Jatinder Singh Bhangu vs. Union of India and Jasjit Singh vs. Union of India. The Court noted that in Jatinder Singh Bhangu's case, it was held that the scheme of faceless assessment, as evident from Section 151A and Clause 3(b) of the notification dated 29.03.2022, is applicable from the stage of show cause notice under Section 148. The Court emphasized that the object of faceless assessment would be defeated if the show cause notice under Section 148 is issued by the Jurisdictional Assessing Officer, and that departmental instructions 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. The impugned notice was set aside on the ground of being issued by the wrong authority.

The High Court held that the case of the petitioner was covered by the judgments in Jatinder Singh Bhangu and Jasjit Singh (supra). Consequently, in terms of the law laid down in those judgments, the impugned notice dated 23.03.2024, issued by the Jurisdictional Assessing Officer, was quashed. The Court granted liberty to the respondents (Income Tax Department) to proceed against the petitioner in accordance with law. No specific issue was left undecided; the court directly addressed the validity of the notice based on the cited precedents.

The High Court allowed the petition. It quashed the impugned notice dated 17.06.2025 issued by the Jurisdictional Assessing Officer. The Court reasoned that the case was covered by its own previous judgments in Jatinder Singh Bhangu and Jasjit Singh (supra), which had dealt with similar challenges to Section 148 notices issued in contravention of the faceless assessment scheme. The revenue had not disputed this position. The quashing of the notice was with liberty to the respondents to proceed against the petitioner in accordance with law. No other issue was expressly left undecided.

The High Court allowed the petition. It was held that the impugned notice dated 31.03.2025, issued by the Jurisdictional Assessing Officer, was liable to be quashed in terms of the law laid down in the judgments of Jatinder Singh Bhangu and Jasjit Singh (supra). The reasoning was that the respondents did not dispute that the petitioner's case was covered by these previous judgments, which had established that notices under Section 148 should adhere to the faceless assessment scheme. The court quashed the notice with liberty to the respondents to proceed against the petitioner in accordance with law. No issue was expressly left undecided.

The High Court held that the impugned notice dated 29.03.2025, issued under Section 148 of the Income Tax Act, 1961, by the Jurisdictional Assessing Officer, was invalid. The Court found that the respondents-Income Tax Department did not dispute the fact that the petitioner's case was covered in their favor by the law laid down in the two judgments previously rendered by different Co-ordinate Benches of the same Court in Jatinder Singh Bhangu’s and Jasjit Singh’s cases. Consequently, in light of the law laid down in those precedents, the Court quashed the impugned notice. The respondents were granted liberty to proceed against the petitioner in accordance with law. No issue was expressly left undecided.

The High Court held that the impugned notice dated 25.06.2025, 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 precedent set by two earlier judgments of the same Court in Jatinder Singh Bhangu's case and Jasjit Singh's case. The Court found that the respondents-Income Tax Department did not dispute that the petitioner's case was covered by the law laid down in those judgments. Consequently, the Court quashed the impugned notice, while granting liberty to the respondents to proceed against the petitioner in accordance with the law. The petition was allowed in these terms.

The High Court held that the impugned notice dated 31.07.2022, issued by the Jurisdictional Assessing Officer, was invalid. This decision was based on the law laid down in the judgments of Jatinder Singh Bhangu and Jasjit Singh, which established that notices under Section 148 should be issued through the faceless assessment procedure as per the notification dated 29.03.2022. The Court quashed the impugned notice. The reasoning was that the respondents did not dispute the applicability of the precedent set by the earlier judgments. The operative direction was to quash the notice with liberty to the respondents to proceed against the petitioner in accordance with law. No issue was expressly left undecided.

The High Court, noting 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, disposed of the present writ petition. The Court directed the Appellate Authority to decide the pending appeal in terms of the aforesaid judgments. The reasoning in Jatinder Singh Bhangu's case indicated that Section 151A of the Act, read with notification dated 29.03.2022, clearly applies the faceless assessment scheme from the stage of show cause notice under Section 148. The Court in that case held that the mandate of Section 144B and 151A read with the notification is lucid, and departmental circulars or instructions cannot override statutory provisions. The operative direction was to the Appellate Authority to decide the appeal in line with the precedents, granting liberty to the revenue to follow the prescribed procedure if so advised.

The High Court held that the impugned notice dated 28.03.2025, 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, Jatinder Singh Bhangu and Jasjit Singh. The court found that the respondents did not dispute that these judgments applied to the present case. Consequently, the impugned notice was quashed. The respondents were granted liberty to proceed against the petitioner in accordance with the law. No other issues were expressly left undecided.

The High Court of Punjab & Haryana, in light of the submissions made and the precedents relied upon, held that the impugned notice dated 31.07.2022, issued by the Jurisdictional Assessing Officer, was not in accordance with the law. The Court followed its own previous decisions in Jatinder Singh Bhangu and Jasjit Singh. Consequently, the Court quashed the notice dated 31.07.2022. The respondents were granted liberty to proceed against the petitioner in accordance with law, implying they could issue a fresh notice if permissible under the prevailing rules and procedures. The petition was allowed in terms of quashing the notice.

The High Court held that the appeal was to 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 under Rs. 2 crores. Consequently, the revenue had specific instructions to withdraw the appeal in view of Circular No. 9 of 2024 dated September 17, 2024, issued by the Ministry of Finance, Department of Revenue, CBDT, Government of India. The Tribunal's order dated July 28, 2021, was not adjudicated on merits. The operative direction was to dismiss the appeal as withdrawn. No issues were left undecided.

The High Court noted the submission of the learned counsel for the appellant (Revenue) that the tax effect involved in the appeal was under Rs. 2 crores and that he had specific instructions to withdraw the appeal in view of Circular No. 9 of 2024 dated September 17, 2024, issued by the Ministry of Finance, Department of Revenue, CBDT, Government of India. Accordingly, the appeal was dismissed as withdrawn. No decision was made on the merits of the original appeal filed before the Tribunal. The operative direction was to dismiss the appeal as withdrawn.

The High Court held that the impugned order of the Commissioner of Income Tax (Exemptions) was unsustainable. The Court found that the CIT had dismissed the petitioner's application for condonation of delay solely on the ground of the petitioner being a habitual late filer for earlier assessment years (2020-21 and 2021-22), without considering the specific grounds and hardships presented by the petitioner for the assessment year 2022-23. The Court noted that the delays in earlier years had themselves been condoned by higher authorities. Therefore, the CIT was required to consider the petitioner's application for condonation of delay for the assessment year 2022-23 independently and on its merits. The Court set aside the impugned order and allowed the petitioner to present its application for condonation of delay to the CIT for a reasoned decision.

The High Court held that the impugned notice dated 09.06.2025, issued under Section 148 of the Income Tax Act, 1961, by the Jurisdictional Assessing Officer, was liable to be quashed. This decision was based on the law laid down in the coordinate bench judgments of Jatinder Singh Bhangu vs. Union of India and Jasjit Singh vs. Union of India. The court found that the respondents did not dispute that these precedents covered the present case. Consequently, the notice was quashed with liberty to the respondents to proceed against the petitioner in accordance with law. The court did not leave any issue undecided.

The High Court held that the impugned notice dated April 18, 2024, 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, namely *Jatinder Singh Bhangu Vs. Union of India* and *Jasjit Singh Vs. Union of India*. In those judgments, the court had ruled that notices issued in a "faceless assessment" manner, contrary to the prevailing notifications, were invalid. The court found that the respondents did not dispute that the petitioner's case fell within the ambit of these precedents. Consequently, the court quashed the notice and granted liberty to the respondents to proceed against the petitioner in accordance with the law. No other issues were expressly left undecided.

The High Court held that the case of the petitioner was covered by the law laid down in the two previous judgments of the Court, namely Jatinder Singh Bhangu Vs. Union of India and others and Jasjit Singh Vs. Union of India and others. Consequently, the impugned notice issued under Section 148 of the Income Tax Act, 1961, by the Jurisdictional Assessing Officer, which was challenged on the grounds of being issued in a faceless assessment manner, was quashed. The Court granted liberty to the respondents (Income Tax Department) to proceed against the petitioner in accordance with law. The petition was allowed in the above terms.

The High Court held that the impugned notice dated 04.06.2025, 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) and CWP No.21509 of 2023 (Jasjit Singh). The Court noted that the respondents did not dispute that these precedents covered the petitioner's case. The reasoning was that the notification dated 29.03.2022 mandated faceless assessment, making the issuance of the notice by the jurisdictional officer impermissible. The ratio decidendi is that notices under Section 148 must adhere to the faceless assessment procedure prescribed by government notifications. Consequently, the impugned notice was quashed, with liberty granted to the respondents to proceed against the petitioner in accordance with law. No issue was expressly left undecided.

The High Court held that the impugned notice dated 03.06.2025, issued under Section 148 of the Income Tax Act, 1961, by the Jurisdictional Assessing Officer, was invalid. This decision was based on the principle laid down in the Court's previous judgments in Jatinder Singh Bhangu's case and Jasjit Singh's case. The Court found that the respondents did not dispute that these precedents covered the present case. Consequently, the impugned notice was quashed. The respondents were granted liberty to proceed against the petitioner in accordance with the law. No other issues were expressly left undecided.

The High Court held that the impugned notice dated 31.07.2022, issued by the Jurisdictional Assessing Officer, was invalid. This decision was based on the law laid down in the previously decided cases of Jatinder Singh Bhangu and Jasjit Singh by coordinate benches of the same High Court. The reasoning was that the notification mandating faceless assessment for notices under Section 148 had not been followed. Consequently, the impugned notice was quashed. The respondents were granted liberty to proceed against the petitioner in accordance with law. No issue was expressly left undecided.

The High Court held that the petitioner would 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). Based on the consensus between the parties, the petition was allowed in terms of the Jyoti Sareen case. Consequently, the notice dated 28.06.2025 issued to the petitioner under Section 148 of the Income Tax Act, 1961, and any consequential proceedings were quashed. The ratio decidendi is that where parties agree to a precedent being applied, the court will follow that precedent to grant similar relief. No issue was expressly left undecided.

The High Court held that the petitioner is 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). Consequently, the impugned notice dated 28.06.2025 issued to the petitioner under Section 148 of the Income Tax Act, 1961, along with any consequential proceedings, was quashed. The reasoning is based on the consensus reached by the parties and the precedent set in the Jyoti Sareen case. The ratio decidendi is that if parties agree to parity with a previous judgment, and that judgment granted specific relief, the same relief should be extended. The operative direction is the quashing of the notice and consequential proceedings.

The High Court of Punjab & Haryana at Chandigarh, in its order dated 10.09.2026, decided that the present writ petition (CWP-20586-2025) would be governed by the detailed judgment passed in CWP No.15791 of 2024 - Jyoti Sareen Vs. Union of India and others. Consequently, no independent findings or reasoning are provided for the specific issues raised by Deepak Dhamija in this particular petition. The operative direction is to follow the decision in the connected case. Any pending miscellaneous applications were also disposed of. The judgment does not record any issue as expressly left undecided.

The High Court held that the impugned notice dated 27.03.2025, issued by the Jurisdictional Assessing Officer, was liable to be quashed. The reasoning was based on the precedent set by two coordinate benches of the same court in the cases of Jatinder Singh Bhangu and Jasjit Singh. These judgments established that notices under Section 148 of the Income Tax Act, 1961, should be issued through the faceless assessment procedure as stipulated 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 the law. No issues were expressly left undecided.

The High Court held that the impugned notice dated 17.06.2025, 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 precedent set by two coordinate benches of the same court in Jatinder Singh Bhangu vs. Union of India and Jasjit Singh vs. Union of India. The reasoning was that the notification dated 29.03.2022 from the Ministry of Finance mandated that such notices be issued through faceless assessment, and therefore, issuance by the Jurisdictional Assessing Officer was impermissible. The court quashed the notice with liberty to the respondents to proceed against the petitioner in accordance with law. The ratio decidendi is that notices under Section 148 must adhere to the faceless assessment procedure as mandated by relevant government notifications.

The High Court held that the impugned notice dated March 28, 2025, issued by the Jurisdictional Assessing Officer to the petitioner under Section 148 of the Income Tax Act, 1961, was invalid. This decision was based on the reasoning that the notice was issued contrary to the mandate of the notification dated March 29, 2022, which required such notices to be issued through a faceless assessment process. The Court followed the precedent set by its own coordinate benches in the cases of Jatinder Singh Bhangu and Jasjit Singh. Consequently, the Court quashed the impugned notice, granting liberty to the respondents to proceed against the petitioner in accordance with the law. No issue was expressly left undecided.

The High Court allowed the writ petition, disposing of it in terms of previous judgments by a Co-ordinate Bench in Jatinder Singh Bhangu's case and Jasjit Singh's case. These prior judgments had allowed writ petitions on similar issues, holding that the scheme of faceless assessment, as evident from Section 151A and notification dated 29.03.2022, applies from the stage of show cause notice under Section 148. The Court reasoned that the object of faceless assessment would be defeated if a jurisdictional Assessing Officer issued such notices, and that statutory provisions, not office memorandums or departmental instructions, are binding. 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, disposing of it in terms of the judgments in Jatinder Singh Bhangu's case and Jasjit Singh's case. These prior judgments had allowed writ petitions on the same issue, finding 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 reasoned that the object of faceless assessment would be defeated if a jurisdictional Assessing Officer issued such notices. While circulars and instructions from the Board cannot override statutory provisions, the mandate of Section 144B and 151A, read with the relevant notification, was found to be lucid and unambiguous. The revenue was granted liberty to follow the procedure as 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, disposing of it in terms of previous judgments by a Co-ordinate Bench in Jatinder Singh Bhangu's case and Jasjit Singh's case. These prior judgments had allowed similar writ petitions on the same issue. The reasoning cited from Jatinder Singh Bhangu's case highlighted that Section 151A of the Act and Clause 3(b) of 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 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 prescribed procedure under the Act, 1961, and proceed accordingly if so advised. The operative direction was to dispose of the writ petition in terms of the aforementioned judgments.

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 adopted by the coordinate bench in Jatinder Singh Bhangu's case was that Section 151A of the Act, read with 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 148/148A. The Court found no ambiguity in the statutory provisions and held that circulars, instructions, or letters issued by the Board or other authorities cannot override statutory provisions. The ratio decidendi is that the mandate of Section 144B and Section 151A, read with the relevant notification, is clear, and the issuance of a Section 148 notice by a jurisdictional Assessing Officer defeats the object of faceless assessment. The revenue was granted liberty 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 allowed the writ petition, disposing of it in terms of the decisions 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. The reasoning cited from Jatinder Singh Bhangu's case emphasizes that Section 151A of the Act, read with Clause 3(b) of the notification dated March 29, 2022, clearly indicates the applicability of the faceless assessment scheme from the stage of a 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 ratio decidendi is that notices under Section 148 must be issued in accordance with the faceless assessment scheme, and jurisdictional Assessing Officers lack the authority to issue them if the scheme applies. The operative direction granted liberty to the revenue to follow the procedure as 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 decisions in Jatinder Singh Bhangu vs. Union of India and others and Jasjit Singh vs. Union of India and others. The reasoning, as per the cited judgments, is that Section 151A of the Income Tax Act, 1961, and the scheme of faceless assessment, including the notification dated March 29, 2022, clearly indicate that the scheme is applicable from the stage of show cause notice under Section 148. Clause 3(b) of the notification explicitly states the scheme's applicability to notices under Section 148. The Court emphasized that assessment proceedings commence with the issuance of a show cause notice and that 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 statutory provisions like Section 144B and 151A, read with the notification, is lucid, and no office memorandum or instruction can override these statutory provisions. The revenue was granted liberty 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 of the same Court had previously allowed writ petitions on identical issues 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 evident from Section 151A and the notification dated March 29, 2022, applies 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. The mandate of statutory provisions like Section 144B and 151A read with the notification was considered lucid and unambiguous. 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.

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, as per the cited judgments, was that Section 151A of the Income Tax Act, 1961, along with 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 and 148A. Clause 3(b) of the notification explicitly applies the scheme to notices under Section 148. The Court noted 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. 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, is lucid, and no office memorandum or instruction can override these statutory provisions. 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's case and Jasjit Singh's case. The Court noted that in these prior cases, the writ petitions were allowed 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 Clause 3(b) of the notification dated March 29, 2022, clearly indicate the applicability of the faceless assessment scheme from the stage of the show cause notice under Section 148. The Court emphasized that while circulars and instructions cannot override statutory provisions, the mandate of Section 144B and 151A, read with the relevant notification, was lucid and unambiguous, rendering any contrary office memorandum or instruction invalid. The operative direction was to dispose of the petition in line with the precedent, allowing the revenue to re-initiate proceedings correctly.

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, as per the cited judgments, is that Section 151A of the Act, 1961, and the notification dated March 29, 2022, clearly indicate that the scheme of faceless assessment is applicable from the stage of show cause notice under Section 148. Clause 3(b) of the notification explicitly states its applicability to notices under Section 148. The Court noted that assessment proceedings commence with the issuance of a 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, is lucid, and statutory provisions cannot be overridden by office memorandums or other instructions. 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 decisions in Jatinder Singh Bhangu’s case and Jasjit Singh’s case. In those cited cases, the coordinate bench had allowed writ petitions on the same issue. The reasoning was that Section 151A of the Income Tax Act, 1961, 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 that the mandate of Section 144B, Section 151A, and the notification dated March 29, 2022, is lucid, and office memorandums or other instructions cannot override these statutory provisions. The object of faceless assessment would be defeated if the show cause notice under Section 148 is issued by the jurisdictional Assessing Officer. The revenue was granted liberty to follow the procedure laid down under the Act, 1961, and proceed accordingly, if so advised. Any pending applications were also disposed of.

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, as per the cited Jatinder Singh Bhangu judgment, was that Section 151A of the Act, 1961, 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 148/148A. The Court found no ambiguity in the statutory provisions and held that the mandate of Section 144B, 151A, and the notification is lucid. It was further noted that while circulars/instructions from the Board are binding on authorities, courts are not bound by them. However, in this instance, the circular aligned with the statutory provisions. The revenue was granted liberty 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 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, as per Jatinder Singh Bhangu's case, is 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 noted that while circulars and instructions from the Board are binding on authorities, courts are not bound by them. However, the mandate of Section 144B and 151A, read with the notification, is lucid and unambiguous, meaning that office memorandums or other instructions cannot override statutory provisions. The object of faceless assessment would be defeated if a jurisdictional Assessing Officer issues the notice. The revenue was granted liberty to follow the procedure as laid down under the Act, 1961, and proceed accordingly if so advised. No issue was expressly left undecided.

The High Court noted that a co-ordinate bench had previously allowed writ petitions on the same issue raised by the petitioner, in the cases of Jatinder Singh Bhangu and Jasjit Singh, by granting liberty to the revenue to follow the prescribed procedure. In the present case, since an appeal was pending before the Appellate Authority, the writ petition was disposed of with a direction to the Appellate Authority to decide the petitioner's appeal in terms of the aforementioned judgments. The court did not decide the merits of the jurisdictional issue but directed the appellate authority to consider it in light of the precedents. All pending applications were also disposed of.

The High Court held that the impugned notice dated March 29, 2025, issued under Section 148 of the Income Tax Act, 1961, by the Jurisdictional Assessing Officer, was liable to be quashed. This decision was based on the precedent established in the cases of Jatinder Singh Bhangu and Jasjit Singh, supra, which held that such notices must be issued through the faceless assessment procedure as per the notification dated March 29, 2022. The Court found that the respondents' counsel did not dispute this position. Consequently, the impugned notice was quashed, with liberty granted to the respondents to proceed against the petitioner in accordance with the law. The petition was allowed in terms of this relief.

The High Court of Punjab & Haryana at Chandigarh, in light of the consensus between the parties, allowed the petition. The Court quashed the impugned notice dated 06.04.2023 issued to the petitioner under Section 148 of the Income Tax Act, 1961, along with any consequential proceedings. The reasoning was based on the agreement that the petitioner was entitled to the same relief as granted in the case of Jyoti Sareen Vs. Union of India and others (CWP No.15791 of 2024) decided on 10.09.2026. The operative direction was the quashing of the notice and consequential actions. No issues were expressly left undecided.

The High Court, based on the consensus reached between the learned counsel for the petitioner and the respondents (Income Tax Department), allowed the petition. The Court's decision was in terms of the relief granted in the judgment dated 10.09.2026 in CWP No.15791 of 2024 (Jyoti Sareen Vs. Union of India and others). Consequently, the impugned notice dated 31.03.2025, issued to the petitioner under Section 148 of the Income Tax Act, 1961, was quashed. Any consequential proceedings arising from this notice were also quashed. The ratio decidendi is that where parties agree to a precedent set by the same court, the court will follow that precedent to grant similar relief. All pending miscellaneous applications were also disposed of.

The High Court of Punjab and Haryana disposed of the petition in terms similar to the judgments in Jatinder Singh Bhangu Vs. Union of India and others and Jasjit Singh Vs. Union of India and others. In those referred cases, writ petitions involving similar issues concerning the validity of notices issued under Section 148 of the Income Tax Act, 1961, were allowed. The court granted liberty to the respondents (Income Tax Department) to follow the procedure laid down under the Act, 1961, and proceed accordingly, if they were so advised. The reasoning implies that the jurisdictional assessing officer may not have had the authority to issue the notice under the prevailing faceless assessment regime, aligning with the petitioner's primary contention. The operative direction is to dispose of the current petition based on the precedent.

The High Court held that the impugned notice dated 27.06.2025, issued under Section 148 of the Income Tax Act, 1961, by the Jurisdictional Assessing Officer, was invalid. This decision was based on the principle established in the cases of Jatinder Singh Bhangu and Jasjit Singh, which were relied upon by the petitioner. The Court found that the respondents did not contest the applicability of these precedents. Consequently, the notice was quashed. The respondents were granted liberty to proceed against the petitioner in accordance with law. No other issue was expressly left undecided.

The High Court allowed the petition in terms of the judgment in Jyoti Sareen’s case. The court quashed the impugned notice dated 25.06.2025 issued to the petitioner under Section 148 of the Income Tax Act, 1961, along with any consequential proceedings. The reasoning for this decision is based on the consensus reached by the counsel for both parties, agreeing that the petitioner should receive the same relief as granted in the aforementioned precedent. The ratio decidendi is that where parties agree to extend the benefit of a prior judgment to a subsequent case, the court will uphold this consensus, leading to the quashing of the reassessment notice. No issue was left undecided.

The High Court held that the petitioner would be entitled to the same relief as granted in the judgment dated 10.09.2026 in CWP No.15791 of 2024 (Jyoti Sareen Vs. Union of India and others). Based on this consensus, the Court allowed the petition. The impugned notice dated 04.04.2025 issued to the petitioner under Section 148 of the Income Tax Act, 1961, along with any consequential proceedings, were quashed. The ratio decidendi is that where parties agree to parity with a prior judgment on similar facts, the Court will extend the same relief. All pending miscellaneous applications were also disposed of.

The High Court, in light of the consensus between the petitioner and the respondent, allowed the petition. The Court quashed the impugned notice dated 25.06.2025 issued to the petitioner under Section 148 of the Income Tax Act, 1961, along with any consequential proceedings. The reasoning was based on the agreement of the parties to follow the relief granted in the High Court's previous judgment dated 10.09.2026 in CWP No.15791 of 2024 (Jyoti Sareen Vs. Union of India and others). The ratio decidendi is that where parties agree to follow a binding precedent of the same court, the court will grant the same relief. The operative direction was the quashing of the notice and consequential proceedings. No issue was expressly left undecided.

The High Court of Punjab & Haryana at Chandigarh held that, by consensus between the learned counsel for the parties, the petitioner would be entitled to the same relief as granted in the judgment dated 10.09.2026 in CWP No.15791 of 2024 (Jyoti Sareen Vs. Union of India and others). Consequently, the petition was allowed, and the impugned notice dated 25.06.2025 issued to the petitioner under Section 148 of the Income Tax Act, 1961, along with any consequential proceedings, was quashed. The reasoning is based on the parties' agreement to follow the precedent set in the Jyoti Sareen case. The ratio decidendi is that where parties agree to a specific outcome based on a prior binding precedent of the same court, the court will grant that relief. Any pending miscellaneous applications were also disposed of.