Punjab & Haryana High Court Judgments — 2026

The High Court of Punjab & Haryana at Chandigarh, in its order dated 23.09.2026, decided that the present writ petition (CWP-18817-2023) would be governed by the detailed judgment passed on the same date in CWP No. 18800 of 2023, titled Rajbir Singh Vs. Principal Commissioner of Income Tax, Panchkula and others. Consequently, no independent decision or reasoning on the specific facts and issues pertaining to Ravi Kumar Gupta's case is provided in this excerpt. The operative direction is to follow the decision in the connected case. Any pending miscellaneous applications were also disposed of.

The High Court did not decide the specific issues of this case independently. Instead, it directed that the order for CWP-18881-2023 be passed in accordance with the detailed judgment issued on the same date in CWP No. 18800 of 2023 (Rajbir Singh Vs. Principal Commissioner of Income Tax, Panchkula and others). Consequently, the findings, reasoning, and ratio decidendi of the present case are subsumed within the aforementioned detailed judgment. The operative directions for this petition would therefore be those stipulated in the judgment for CWP No. 18800 of 2023. No issue was expressly left undecided; rather, the decision was deferred to a related, more detailed judgment.

The High Court of Punjab & Haryana at Chandigarh, in its order dated 23.09.2026, decided that the present writ petition (CWP-18854-2023) would follow the detailed judgment of even date passed in CWP No. 18800 of 2023, Rajbir Singh Vs. Principal Commissioner of Income Tax, Panchkula and others. Consequently, the High Court disposed of all pending miscellaneous applications in this case. The specific findings, reasoning, and ratio decidendi pertaining to the issues raised by Satish Sharma are not elaborated in this particular order, as it defers to the judgment in the companion case. No specific relief granted or issue left undecided is recorded.

The High Court of Punjab & Haryana at Chandigarh, in its oral order, stated that the decision for this writ petition (CWP-18858-2023) would be based on the detailed judgment of even date passed in a connected writ petition, CWP No. 18800 of 2023, titled Rajbir Singh Vs. Principal Commissioner of Income Tax, Panchkula and others. Consequently, no independent findings or reasoning specific to Rajni Kumar's case are recorded in this excerpt. The operative directions are to follow the decision in the connected case and to dispose of all pending miscellaneous applications.

The High Court, in its oral order, stated that the present writ petition (CWP-18814-2023) was being disposed of in terms of the detailed judgment of even date passed in CWP No. 18800 of 2023 - Rajbir Singh Vs. Principal Commissioner of Income Tax, Panchkula and others. This implies that the outcome for Subhash Chand's petition mirrors that of Rajbir Singh's petition. The judgment does not provide the specifics of the decision in the related case or the reasoning behind it. Consequently, the specific findings, reasoning, ratio, and operative directions for this case are not recorded in this particular order, other than the reference to the other judgment.

The High Court has not provided a decision on the merits of the case in this specific order. Instead, it has directed that the order for this petition will be the same as the detailed judgment passed in CWP No. 18800 of 2023 on the same date. This implies that the outcome and reasoning for Raj Kumar Gaba's petition are contingent upon the decision in the Rajbir Singh case. No specific findings, reasoning, or operative directions are provided for this petition independently. Any pending miscellaneous applications have been disposed of.

The High Court has not provided a specific finding or reasoning for this particular writ petition. Instead, it has directed that the order for this case is to be found in the detailed judgment of even date passed in CWP No. 18800 of 2023. Therefore, the specific holdings, reasoning, and ratio decidendi for Sudha Pande's case are not detailed in this order. Any operative directions or relief granted would be as per the aforementioned connected judgment. No issue was expressly left undecided.

The High Court held that the concurrent findings of the CIT(A) and the Tribunal that the appellant failed to show sufficient cause for the delay were correct and did not warrant interference. The explanation provided by the assessee accounted for the period until the counsel resumed office on 15.03.2017, but offered no substantiation for the subsequent nearly eleven-month period of alleged illness until the appeal was filed on 22.02.2018. No medical records or other supporting material were produced. The Court noted the assessee's own lack of cooperation at the assessment stage, which reflected on the assessee himself and not solely on the counsel. The reliance on Rafiq v. Munshi Lal was distinguished, as in that case, the party had done everything in their power, unlike the present situation where inaction and negligence were evident. The Court concluded that no substantial question of law arose, and the appeal was dismissed.

The High Court has not provided a specific decision or reasoning for this particular writ petition. Instead, it has directed that the order for this case will be the same as the detailed judgment passed in CWP No. 18800 of 2023. Therefore, the findings, reasoning, and operative directions for this case are contingent upon the decision in the aforementioned connected writ petition. Any pending miscellaneous applications have been disposed of.

The High Court held that the impugned order dated January 19, 2022, passed by the PCIT, was bad in law and unsustainable. The Court found that the PCIT did not apply the tests laid down in Circular No. 9/2015. The Court distinguished between Section 5 of the Limitation Act, 1963, which requires "sufficient cause," and Section 119(2)(b) of the Income Tax Act, which empowers the Board to admit claims after the statutory period to avoid genuine hardship. The Court noted that Circular No. 9/2015, relied upon by the department itself, requires the authority to examine the correctness and genuineness of the income/loss declared and whether the case is one of genuine hardship. The Court found that the petitioner's explanation for the delay, stemming from the evolving legal position in similar cases, was a valid reason for seeking condonation. The Court quashed the PCIT's order and remitted the matter back to the PCIT to consider the petitioner's application for condonation of delay afresh, after affording an opportunity of hearing. The Court expressed no opinion on the merits of the petitioner's claim for refund.

The High Court did not render any decision on the merits of the case. Instead, it directed that the order for this petition should be seen in the detailed judgment of even date passed in a connected writ petition, CWP No.18800 of 2023, titled Rajbir Singh Vs. Principal Commissioner of Income Tax, Panchkula and others. Consequently, no specific findings were made, no reasoning was provided, and no ratio decidendi can be extracted from this order. Any pending miscellaneous applications were also disposed of.

The High Court has not provided a substantive decision or reasoning in this order. It merely states that the detailed judgment for this case is contained within the judgment of an associated writ petition, CWP No. 18800 of 2023. Consequently, no specific findings, ratio decidendi, or operative directions are discernible from this particular order. The court has also indicated that all pending miscellaneous applications, if any, have been disposed of.

The High Court allowed the petitioner's request to withdraw the writ petition. The Court noted that the petitioner had filed another petition for the same relief, which had already been allowed on 22.09.2026. Consequently, the present petition was dismissed as withdrawn. The Court also directed that any pending applications filed in this petition would also stand disposed of. No specific legal provisions were discussed or applied in reaching this decision, as the matter was disposed of on the petitioner's request for withdrawal.

The Tribunal (High Court) decided to allow the petitioner's request to withdraw the writ petition. The court granted the petitioner liberty to file a fresh petition on the same cause of action, which also included the challenge to Section 147A of the Income Tax Act, 1961. Consequently, any pending applications related to this petition were also disposed of. The court's decision was based on the petitioner's explicit request for withdrawal and liberty to refile. No adjudication on the merits of the case or the challenge to Section 147A occurred.

The High Court held that the impugned penalty order passed under Section 270A of the Income-tax Act, 1961, was liable to be set aside. The Court noted the admitted position that the petitioner was not granted a personal hearing despite seeking one. In light of this admission and in terms of Section 274 of the Act, which mandates granting an opportunity of being heard, the Court set aside the order. The respondent-Income Tax Department was granted liberty to pass a fresh reasoned order, but only after affording the petitioner an opportunity of personal hearing in accordance with law. The petition was allowed in the above terms.

The Tribunal held that the parties had agreed that the present appeal is covered in favour of the appellant-assessee through the judgment of a Division Bench of the Court dated 26.02.2026 in ITA-517-2008, concerning M/s Vardhman Textiles Ltd. vs. Commissioner of Income Tax and another. Consequently, the questions of law raised in the present appeal were answered in favour of the appellant-assessee, and the appeal was allowed in terms of the law laid down in the Vardhman Textiles Ltd. case. Any pending miscellaneous applications were also disposed of. The specific findings or ratio decidendi from the Vardhman Textiles Ltd. case were not detailed in this judgment, but the principle applied is that if a prior Division Bench judgment on similar facts and issues is binding, and both parties agree to its applicability, the present appeal should follow that precedent.

The Tribunal noted the submission made by the learned counsel for the appellant-revenue. The counsel stated that the respondent-council is no longer in operation and, therefore, requested permission to withdraw the appeal with liberty to revive it if the need arises. The Court accepted this submission and accordingly dismissed the appeal as withdrawn with the liberty as prayed for. The Court did not decide on the merits of the case. No specific findings were made on any substantive legal issues, as the appeal was disposed of on a procedural ground.

The High Court permitted the appellant-revenue to withdraw the appeal. The reasoning provided is that the learned counsel for the appellant-revenue submitted that the order under challenge is no longer in operation. Consequently, the appeal was dismissed as withdrawn, with liberty granted to the appellant-revenue to revive the appeal if the need arises. No specific findings were made on the merits of the case, and no issues were left undecided as the appeal was withdrawn.

The Tribunal held that the present appeal is allowed in terms of the judgment of a Division Bench of the High Court dated 26.02.2026 in ITA-517-2008, concerning M/s Vardhman Textiles Ltd. vs. Commissioner of Income Tax and another. The court noted that learned counsel for both the appellant-assessee and the respondent-revenue agreed that the appeal was covered in favour of the assessee by the aforementioned judgment. Consequently, the questions of law raised through this appeal were answered in favour of the appellant-assessee, and the appeal itself was allowed in terms of the law laid down in the Vardhman Textiles Ltd. case. Any pending miscellaneous applications were also disposed of in light of this consensus. The specific reasoning from the Vardhman Textiles Ltd. case was not detailed in this excerpt, but it formed the basis for the decision.

The High Court allowed the petitioner's request to withdraw the writ petition. The court granted liberty to the petitioner to file a fresh petition on the same cause of action. Furthermore, the petitioner was granted liberty to challenge Section 147A of the Income-tax Act, 1961, in the fresh petition. The court did not decide the merits of the original petition. The operative direction was to dismiss the petition as withdrawn with the specified liberty.

The High Court of Punjab and Haryana at Chandigarh, comprising Hon'ble Mr. Justice Deepak Sibal and Hon'ble Mr. Justice Sunish Bindlish, decided to allow the withdrawal of the petition. The reasoning provided is that the petitioner's counsel sought to withdraw the petition because the relief sought had already been granted in another petition, CWP-20110-2026, by an order dated 10.09.2026. The Tribunal accepted this request. The operative direction was to dismiss the petition as withdrawn. No issues were expressly left undecided.

The High Court noted that the learned counsel for the petitioner sought to withdraw the petition. The reason for withdrawal was that the relief claimed by the petitioner in the present writ petition had already been granted in another petition, CWP-19124-2026, vide an order dated 10.09.2026. Consequently, the High Court dismissed the petition as withdrawn. No decision on the merits of the tax dispute was made. The operative direction was to dismiss the petition as withdrawn.

The High Court held that, in light of the consensus between the parties, the petitioner is entitled to the same relief as granted in the case of Jyoti Sareen vs. Union of India and others (CWP-15791-2024). Consequently, the impugned notice dated 25.03.2023 issued to the petitioner under Section 148 of the Income Tax Act, 1961, along with any consequential proceedings, was quashed. The reasoning was based on the agreement of the counsel for both the petitioner and the revenue. The ratio decidendi is that where parties agree to a specific outcome based on a prior judgment of the same court, the court will grant that relief. No issues were expressly left undecided.

The High Court, based on the consensus between the petitioner and the respondents, allowed the petition. The Court quashed the impugned notice dated 17.03.2025 issued to the petitioner under Section 148 of the Income Tax Act, 1961, and any consequential proceedings. The reasoning is that the parties agreed to apply the precedent set by the Court's judgment in CWP-15791-2024 (Jyoti Sareen vs. Union of India and others). The ratio decidendi is that where parties agree to follow a prior binding precedent on similar facts, the court will grant the same relief. No issues were expressly left undecided.

The High Court held that the petitioner is entitled to the same relief as granted in the case of Jyoti Sareen vs. Union of India and others (CWP-15791-2024). Based on this consensus between the parties, the petition was allowed. Consequently, the impugned notice dated 30.06.2026 issued to the petitioner under Section 148 of the Income Tax Act, 1961, was quashed, along with any consequential proceedings. The reasoning is based on the agreement of the parties to follow the precedent set in the Jyoti Sareen case. The ratio decidendi is that where parties agree to parity with a previous judgment, the court will grant similar relief. No issues were left undecided.

The High Court of Punjab and Haryana at Chandigarh, comprising Hon'ble Mr. Justice Deepak Sibal and Hon'ble Mr. Justice Sunish Bindlish, allowed the petition. The decision was based on the consensus between the parties that the petitioner would receive 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 30.03.2023 issued to the petitioner under Section 148 of the Income Tax Act, 1961, along with any consequential proceedings, was quashed. The ratio decidendi is that where parties agree to a specific outcome based on a prior judicial precedent, the court will uphold that agreement and grant the consequential relief.

The High Court held that the issue in the present appeal was no longer res integra and stood concluded by its previous judgment in C.S. Atwal v. Commissioner of Income Tax, Ludhiana, dated 22.07.2015. In that case, the Court had examined identical Joint Development Agreements, the scope of Section 2(47)(ii), (v), and (vi) of the Income Tax Act, 1961, the requirements of Section 53A of the Transfer of Property Act, 1882, the nature of possession delivered, and the question as to whether the transaction gave rise to taxable capital gains. The Court found that the facts and issues involved in the present appeal were identical to those in C.S. Atwal. Therefore, no independent consideration was required, and the appeal was disposed of in terms of the aforesaid judgment.

The High Court allowed the petition in terms of the judgment passed in CWP-15791-2024 (Jyoti Sareen vs. Union of India and others). The Court quashed the impugned notice dated 24.03.2024 issued to the petitioner under Section 148 of the Income Tax Act, 1961, along with any consequential proceedings. The reasoning is based on the consensus between the parties that the petitioner should receive the same relief as granted in the cited precedent. The ratio decidendi is that if parties agree that a case is on all fours with a prior binding precedent, the same relief should be extended. The operative direction is the quashing of the Section 148 notice and consequential actions. 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 & others). Based on this consensus between the parties, the petition was allowed. The impugned notice dated 28.08.2024, 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 agreement of the parties to follow the precedent established in the Jyoti Sareen case. The ratio decidendi is that if parties agree to a specific relief based on a prior High Court judgment, the court will grant that relief and quash the impugned notice and proceedings.

The High Court of Punjab and Haryana at Chandigarh, based on the consensus reached by the learned counsel for both the petitioner and the respondents, allowed the petition. The court directed that the petitioner would be entitled to the same relief as had been 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 30.06.2025, issued to the petitioner under Section 148 of the Income Tax Act, 1961, was quashed, along with any consequential proceedings. The reasoning is based entirely on the agreement of the parties 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 judgment of the same court, the court will grant that relief. No issues were expressly left undecided.

The High Court of Punjab and Haryana at Chandigarh, in light of the consensus between the parties, allowed the petition. The Court quashed the impugned notice dated 17.03.2025 issued to the petitioner under Section 148 of the Income Tax Act, 1961, and any consequential proceedings. The reasoning was based on the agreement of the parties that the petitioner should receive the same relief as granted in the prior judgment of the Court in CWP-15791-2024 (Jyoti Sareen vs. Union of India and others). The operative direction was the quashing of the notice and consequential proceedings. No issues were expressly left undecided.

The High Court of Punjab & Haryana at Chandigarh allowed the petition. The Court, in light of the consensus between the parties, granted the same relief as had been previously 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 12.08.2024 issued to the petitioner under Section 148 of the Income Tax Act, 1961, was quashed, along with any consequential proceedings. The ratio decidendi is that where parties agree to follow a precedent set by the same court, the relief granted in that precedent should be extended. The operative direction was the quashing of the notice and consequential proceedings.

The High Court held that all the substantial questions of law raised by the revenue have been answered against the revenue in a recent judgment of the same court dated 10.09.2026 in CWP No.15791 of 2024, titled Jyoti Sareen Vs. Union of India and others. Consequently, based on the consensus established in the Jyoti Sareen case, the present appeal filed by the revenue is dismissed. The reasoning for the dismissal is directly tied to the precedent set in the Jyoti Sareen judgment, which, according to the High Court, resolves all the issues presented in this appeal in favor of the assessee. No specific findings on individual issues are provided in this judgment, as it relies entirely on the prior ruling. The operative direction is the dismissal of the appeal.

The High Court, while acknowledging that the assessee's conduct in not effectively pursuing proceedings before the authorities cannot be ignored, considered the cost imposed by the ITAT to be on the higher side. The Court noted that a substantial part of the assessment proceedings pertained to the period affected by the Covid-19 pandemic. In light of these peculiar facts and circumstances, the High Court deemed it appropriate to restore the matter for fresh adjudication on merits. The Court reduced the cost from Rs. 2 lakhs to Rs. 25,000/- in each appeal. The assessee was directed to deposit this reduced cost in the Poor Patient Welfare Fund, PGIMER, Chandigarh within four weeks from the date of the order. The Court clarified that, except for the reduction in cost, the ITAT's order dated 25.03.2026 would remain unaltered.

The High Court of Punjab and Haryana at Chandigarh 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 & others. Based on the consensus between the parties, the Court allowed the petition. The reasoning was that both parties agreed to the same outcome as in the Jyoti Sareen case. The ratio decidendi is that if parties agree to a precedent being applied, the court will follow that consensus. The operative direction was to quash the impugned notice dated 28.06.2025 issued under Section 148 of the Income Tax Act, 1961, along with any consequential proceedings. No issues were left undecided.

The High Court observed that the decision on the petitioner's appeal, filed against the assessment order dated 29.12.2017 and subsequently remanded by the ITAT on 05.07.2019, had been unnecessarily delayed. The Court expressed its disapproval of this delay. Consequently, the Court directed the authority now competent to finally decide the petitioner's appeal to do so within two months from the date of receipt of a copy of the High Court's order. The Court did not delve into the merits of the original assessment or the appeal itself, focusing solely on the procedural delay. The ratio decidendi is that excessive and unexplained delay in deciding tax appeals after remand warrants High Court intervention to ensure timely justice.

The High Court, based on the consensus reached between the learned counsel for the parties, allowed the petition. The court held that the petitioner would be entitled to the same relief as granted in the case of Jyoti Sareen (supra). Consequently, the impugned notice dated March 28, 2025, issued to the petitioner under Section 148 of the Income Tax Act, 1961, along with any consequential proceedings, was quashed. The ratio decidendi is that if parties agree to follow a precedent set by the same court in a similar matter, the court will grant the same relief.

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 & others). Based on this consensus between the parties, the Court allowed the petition. The impugned notice dated 22.06.2025, 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 extend the benefit of a prior judgment to a new assessee, and the facts are analogous, the Court will uphold this agreement and grant the same relief. The operative direction was the quashing of the notice and consequential proceedings.

The High Court allowed the petition in terms of the judgment passed in Jyoti Sareen vs. Union of India and others dated 10.09.2026. The Court quashed the impugned notice dated 07.03.2025 issued to the petitioner under Section 148 of the Income Tax Act, 1961, along with any consequential proceedings. The reasoning was based on the consensus between the petitioner and the revenue to grant identical relief as in the cited case. The ratio decidendi is that where parties agree to parity with a previous judgment on similar facts and legal grounds, the court will grant that relief. The operative direction was the quashing of the notice and consequential proceedings.

The High Court of Punjab and Haryana at Chandigarh, in light of the consensus between the parties, allowed the petition. The Court quashed the impugned notice dated 27.03.2025 issued to the petitioner under Section 148 of the Income Tax Act, 1961, and any consequential proceedings. The reasoning was based on the agreement of both the petitioner and the revenue that the petitioner should receive the same relief as was granted in the High Court's previous judgment dated 10.09.2026 in CWP-15791-2024 (Jyoti Sareen vs. Union of India & others). The ratio decidendi is that where parties agree to parity with a previous judgment, the court will grant similar relief. No issue was expressly left undecided.

The High Court held that all the substantial questions of law raised by the revenue had already been answered against the revenue in a recent judgment of the same Court dated September 10, 2026, in CWP No. 15791 of 2024, titled Jyoti Sareen Vs. Union of India and others. Consequently, following the precedent set in Jyoti Sareen's case, the appeal filed by the revenue was dismissed. The reasoning for the dismissal is based on the prior adjudication of the same legal issues by the High Court. The specific findings of the ITAT that were upheld by the High Court, and the detailed reasoning behind the Jyoti Sareen judgment, are not elaborated upon in this order, as it relies on the previous decision. The operative direction is the dismissal of the appeal.

The High Court of Punjab & Haryana at Chandigarh allowed the petition in terms of the judgment passed in Jyoti Sareen's case dated 10.09.2026. Consequently, the impugned notice dated 31.03.2025 issued to the petitioner under Section 148 of the Income Tax Act, 1961, was quashed, along with any consequential proceedings. The reasoning was based on the consensus reached by the learned counsel for both the petitioner and the respondents, agreeing that the petitioner was entitled to the same relief as granted in the Jyoti Sareen case. The operative direction was the quashing of the notice and consequential actions. No issues were expressly left undecided.

The High Court, in light of the consensus between the parties, allowed the petition. The court held that the petitioner is 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 impugned notice dated 17.03.2024 issued to the petitioner under Section 148 of the Income Tax Act, 1961, and any consequential proceedings were quashed. The ratio decidendi is that if parties agree to follow a precedent set by a coordinate bench of the same court, the court will grant the same relief. All pending miscellaneous applications were also disposed of.

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 between the parties, the petition was allowed. The Court quashed the impugned notice dated 22.03.2024 issued to the petitioner under Section 148 of the Income Tax Act, 1961, and any consequential proceedings that may have arisen therefrom. The ratio decidendi is that where parties agree that a case is on all fours with a previously decided case granting specific relief, the same relief should be extended. All pending miscellaneous applications were also disposed of.

The High Court of Punjab & Haryana at Chandigarh 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 between the parties, the petition was allowed. The impugned notice dated 30.08.2024, issued to the petitioner under Section 148 of the Income Tax Act, 1961, was quashed, along with any consequential proceedings. The court also disposed of any pending miscellaneous applications. The specific reasoning behind the relief granted in the Jyoti Sareen case, which formed the basis for this decision, is not detailed in this judgment, but the operative direction is the quashing of the Section 148 notice and related actions.

The High Court allowed the petition, quashing the impugned notice dated 26.05.2022. The decision was based on the concession made by the Revenue before the Supreme Court in the case of Deepak Steel and Power Limited, which was subsequently followed by the Supreme Court. The Supreme Court had noted the Revenue's admission that for assessment year 2015-2016, all notices issued on or after April 1, 2021, would have to be dropped because they would not fall for completion within the period prescribed under the Taxation and other Laws (Relaxation and Amendment of Certain Provisions) Act, 2020. Since the notice in question was dated 25.06.2021, it squarely fell within the scope of this concession. The High Court found no further adjudication necessary given this fair stand by the respondent and the Supreme Court's precedent. No costs were awarded.

The High Court, in light of the consensus between the parties, allowed the petition. The Court quashed the impugned notice dated 20.06.2025 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 that the petitioner should receive the same relief as granted in the High Court's prior judgment in Jyoti Sareen's case. 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 between the parties, allowed the petition. The court held that the petitioner is entitled to the same relief as granted in the case of Jyoti Sareen Vs. Union of India and others. Consequently, the impugned notice dated 31.08.2024 issued to the petitioner under Section 148 of the Income Tax Act, 1961, and all consequential proceedings were quashed. The court also disposed of any pending miscellaneous applications. The ratio decidendi is that when parties agree to a specific outcome based on a prior binding precedent of the same court, the court will grant that relief. The operative direction was the quashing of the Section 148 notice and consequential proceedings.

The High Court, based on the consensus between the petitioner and the respondent, allowed the petition. The Court quashed the impugned notice dated 04.03.2024 issued to the petitioner under Section 148 of the Income Tax Act, 1961, along with any consequential proceedings. The reasoning was that the parties had agreed to apply the same relief 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 proceedings. No issue was expressly left undecided.

The High Court allowed the petition in terms of the judgment passed in Jyoti Sareen’s case dated 10.09.2026. Consequently, the notice dated 04.03.2024 issued to the petitioner under Section 148 of the Income Tax Act, 1961, and all consequential proceedings were quashed. The reasoning was based on the consensus between the learned counsel for the parties that the petitioner was entitled to the same relief as granted in the aforementioned Jyoti Sareen case. The operative direction was the quashing of the impugned notice and consequential proceedings. No issue was expressly left undecided.