Punjab & Haryana High Court Judgments — 2026

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 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 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 Tribunal noted that the learned counsel for the appellant (Revenue) sought to withdraw the appeal. Consequently, the Tribunal ordered that the appeal be dismissed as withdrawn. Any pending applications were also to stand disposed of. The judgment does not delve into the merits of any substantive tax issue, as the appeal was withdrawn by the Revenue.

The High Court held that the present appeal is to be dismissed in light of the judgment of the Supreme Court dated 16.09.2026 passed in Civil Appeal No. 21762 of 2017, titled Assistant Commissioner of Income Tax (Exemptions) Vs. Ahmedabad Urban Development Authority. The reasoning is based on the consensus reached by both learned counsel for the parties, who agreed that the appeal should be decided in the assessee's favour by applying the law laid down by the Supreme Court in the cited case. The operative direction is the dismissal of the appeal. No issue was expressly left undecided.

The High Court held that the petitioner would be entitled to the same relief as granted in CWP-15791-2024 (Jyoti Sareen vs. Union of India), decided on 10.09.2026. Based on the consensus between the parties and in light of the judgment in Jyoti Sareen's case, the petition was allowed. The impugned notice dated 25.06.2026 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 follow a precedent set by a coordinate bench on similar facts and issues, the court should grant the same relief to avoid inconsistency. The operative direction was to quash the notice and all consequential proceedings.

The High Court held that the delay of 34 days in filing the Income Tax Return for AY 2020-21 by the petitioner, a cooperative society, was to be condoned. The Court found that the circumstances leading to the delay, including the spread of COVID-19 and the statutory requirement of routing the audit report through the State department, constituted genuine hardship. The Court criticized the CCIT for adopting a hyper-technical view and interpreting the CBDT circulars in a restrictive manner, by confining consideration to the delay in filing the statutory audit report and insisting on an explanation for each day's delay, contrary to the liberal and benevolent object of the circulars. The Court relied on CBDT Circular No. 13/2023, which empowers Chief Commissioners/Directors General of Income Tax to condone delays due to circumstances beyond the assessee's control and genuine hardship. The Court also referred to the Madras High Court's decision in T943 Vickrapandiyam Primary Agricultural Co-operative Credit Society Ltd. Vs. Chief Commissioner of Income-tax, emphasizing that procedural errors should not deny relief in cases of genuine hardship without tax evasion. Consequently, the impugned order of the CCIT was set aside, the delay was condoned, and the respondents were directed to consider the petitioner's claim for deduction under Section 80P for AY 2020-21 in accordance with law.

The High Court of Punjab and Haryana at Chandigarh, in light of the consensus between the parties and following the precedent set in Jyoti Sareen's case (CWP-15791-2024), allowed the petition. The Court quashed the impugned notice dated 18.06.2026 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 to extend the relief granted in the cited case. The principle established is that if a similar case has been decided favorably and the revenue consents, the same relief should be granted. The operative direction was to quash the notice and proceedings.

The Tribunal held that the petitioner would be entitled to the same relief as has been granted in the case of Jyoti Sareen vs. Union of India (CWP-15791-2024), which was decided on 10.09.2026. This decision was based on a consensus reached between the parties. Consequently, the impugned notice dated 18.03.2024 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 when parties agree to a settlement based on a prior favorable judgment for a similar issue, the court will uphold that consensus to dispose of the matter efficiently. The operative direction was to quash the notice and consequential proceedings.

The High Court of Punjab and Haryana, in light of the consensus between the parties, allowed the petition. The court directed that the petitioner, Anurag Dua, would be entitled to the same relief as was granted in the judgment dated 10.09.2026 in CWP-15791-2024 (Jyoti Sareen vs. Union of India). This relief specifically pertains to the quashing of the impugned notice dated 18.06.2026 issued to the petitioner under Section 148 of the Income Tax Act, 1961, and any consequential proceedings arising therefrom. The court's decision was based on the agreement of the learned counsel for both the petitioner and the respondents, effectively disposing of the matter without a detailed examination of the merits of the Section 148 notice itself.

The High Court, in terms of a consent order and following the precedent set in Jyoti Sareen vs. Union of India, allowed the writ petition. The Court quashed the impugned notice dated 16.06.2026 issued to the petitioner under Section 148 of the Income Tax Act, 1961, and any consequential proceedings. The reasoning was based on the consensus reached by the parties, acknowledging the relief granted in the cited case. The principle established is that if a similar case has been decided favorably based on consent and precedent, the same relief can be extended to another petitioner in a writ proceeding, provided there is agreement between the parties. No issue was expressly left undecided.

The High Court held that, in light of the consensus between the parties, the petitioner was 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 petition was allowed. The impugned notice dated 30.03.2025 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 where parties agree to a specific outcome based on a prior binding precedent, the court will uphold that agreement and apply the precedent accordingly. No issues were 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 10.09.2026 in CWP No.15791 of 2024, titled Jyoti Sareen Vs. Union of India and others. In light of this prior decision, the present appeals were dismissed. The reasoning of the High Court is based on the principle of precedent, where a higher court's decision on identical issues binds lower courts and subsequent benches. The ratio decidendi is that if the jurisdictional High Court has already ruled on the interpretation of 'Faceless Manner' and the powers of the JAO versus FAO in issuing Section 148 notices under the E-Assessment Scheme, then subsequent appeals raising the same questions must follow that ruling. The operative direction was to dismiss the appeals.

The High Court, in light of the consensus reached between the petitioner and the revenue, allowed the petition. The court held that the petitioner was entitled to the same relief as granted in the case of Jyoti Sareen vs. Union of India and others (CWP-15791-2024) dated 10.09.2026. Consequently, the notice dated 06.04.2022, issued to the petitioner under Section 148 of the Income Tax Act, 1961, and all consequential proceedings arising therefrom, were quashed. The ratio decidendi is that where parties agree to a specific outcome based on a prior binding precedent, the court will follow that precedent to grant similar relief. The operative direction was the quashing of the notice and consequential proceedings.

The High Court held that the present petition, pertaining to assessment year 2015-16, was covered by the Supreme Court's judgment in Union of India and others Vs. Rajeev Bansal (supra). The Supreme Court's decision in that case was rendered in favour of the petitioner. In light of this consensus and the binding precedent set by the Supreme Court, the High Court allowed the petition. The impugned notice dated 30.06.2021 was quashed as a result. The ratio decidendi is that if an issue is directly covered by a Supreme Court judgment, the High Court should follow that precedent to grant 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 and others). This consensus between the parties led to the allowance of the petition. The impugned notice dated 27.05.2025, 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 where parties agree to a specific outcome based on a prior, similar judgment of the same court, that outcome should be applied. The operative direction was the quashing of the notice and consequential proceedings.

The Tribunal held that the present appeal is to be dismissed in light of the judgment of the Supreme Court dated 16.09.2026 in Civil Appeal No. 21762 of 2017, Assistant Commissioner of Income Tax (Exemptions) vs. Ahmedabad Urban Development Authority. Both the assessee and the revenue agreed to this course of action. The Tribunal relied on the consensus between the parties and the law laid down by the Supreme Court in the Ahmedabad Urban Development Authority case. The operative direction is the dismissal of the appeal. No issues were expressly left undecided.

The High Court held that based on the consensus between the learned counsel for the parties, 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 petition was allowed. The court quashed the impugned notice dated 28.03.2025 issued to the petitioner under Section 148 of the Income Tax Act, 1961, along with any consequential proceedings. The ratio decidendi is that where parties agree to follow a precedent set by the court in a similar case, the court will grant similar relief. All pending miscellaneous applications were also disposed of.

The High Court held that the petitioner is entitled to the same relief as granted in the judgment dated September 10, 2026, in CWP No. 15791 of 2024 (Jyoti Sareen Vs. Union of India and others). Consequently, the impugned notice dated April 19, 2024, issued to the petitioner under Section 148 of the Income Tax Act, 1961, and any consequential proceedings arising therefrom, were quashed. The reasoning is based on the consensus reached between the parties, wherein both the petitioner and the revenue agreed that the petitioner should receive the same benefit as was awarded in the Jyoti Sareen case. The ratio decidendi is that where parties agree to be bound by a prior judgment of the same court on similar facts, the court will grant the same relief. The operative direction is the quashing of the notice and consequential proceedings. No issue was expressly left undecided.

The High Court held that based on the consensus between the learned counsel for the parties, 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 petition was allowed. The impugned notice dated 28.03.2023 issued to the petitioner under Section 148 of the Income Tax Act, 1961, along with any consequential proceedings, was quashed. The court also disposed of all pending miscellaneous applications. The reasoning is based on the agreed-upon parity with the Jyoti Sareen judgment, implying that the grounds for quashing in that case were applicable here. The ratio decidendi is that where parties agree to extend relief granted in a prior, similar case, the court will follow that consensus to quash notices issued under Section 148 and consequential actions.

The High Court held that the petition is allowed in terms of the judgment passed in Jyoti Sareen’s case (supra). Consequently, the impugned notice dated 08.04.2024 issued to the petitioner under Section 148 of the Income Tax Act, 1961, along with any consequential proceedings, was quashed. The reasoning for this decision is based on the consensus reached by the learned counsel for both parties, who agreed that the petitioner was entitled to the same relief as granted in the Jyoti Sareen case. The ratio decidendi is that when parties agree to extend the benefit of a prior judgment to a subsequent case with similar circumstances or on the basis of precedent, the court will uphold this agreement. The operative direction is the quashing of the Section 148 notice and consequential proceedings. No issue was expressly left undecided.

The High Court of Punjab & Haryana at Chandigarh allowed the petition in terms of the judgment in Jyoti Sareen Vs. Union of India and others (CWP No.15791 of 2024). 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 Court noted a consensus between the parties that the petitioner would be entitled to the same relief as granted in the aforementioned case. The reasoning is based on the application of the precedent set by the Court in the Jyoti Sareen case. The operative direction is the quashing of the impugned notice and consequential proceedings. No issue was expressly left undecided.

The High Court held that based on the consensus between the learned counsel for the parties, 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 petition was allowed. The impugned notice dated 20.05.2026 issued to the petitioner under Section 148 of the Income Tax Act, 1961, along with any consequential proceedings, was quashed. The reasoning is solely 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 a specific outcome based on a prior binding precedent, the court will grant that relief. All pending miscellaneous applications were also disposed of.

The High Court held that the petition is allowed in terms of the judgment passed in Jyoti Sareen’s case (supra). Consequently, the impugned notice dated 09.04.2024 issued to the petitioner under Section 148 of the Income Tax Act, 1961, along with any consequential proceedings, were quashed. The reasoning is based on the consensus reached between the learned counsel for the parties, who agreed that the petitioner was entitled to the same relief as granted in the aforementioned Jyoti Sareen case. The ratio decidendi is that where parties agree to follow a precedent established by the court in a similar matter, the court will grant the same relief. All pending miscellaneous applications were also disposed of.

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 28.06.2025 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 both the petitioner and the revenue that the petitioner should receive the same relief as had been granted in a previous judgment of the Court dated 10.09.2026 in CWP No. 15791 of 2024 (Jyoti Sareen Vs. Union of India and others). The operative direction was the quashing of the Section 148 notice and consequential proceedings. No issue was expressly left undecided. The ratio decidendi is that where parties agree to a specific precedent being applied, the court will follow that consensus to grant similar relief.

The High Court, based on the consensus reached between the learned counsel for the petitioner and the respondent, allowed the petition. The court ordered 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). Consequently, the impugned notice dated 15.04.2024 issued to the petitioner under Section 148 of the Income Tax Act, 1961, and all consequential proceedings were quashed. Any pending miscellaneous applications were also disposed of. The judgment did not specify the exact relief granted in Jyoti Sareen's case, nor did it detail the reasoning behind that prior judgment, as the current decision was based on agreement.

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 also disposed of all pending miscellaneous applications. The judgment does not delve into the merits of any substantive tax dispute or the validity of Section 147A, as the petition was dismissed on procedural grounds of withdrawal.

The High Court held that based on 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. Consequently, the impugned notice dated 21.06.2025, issued to the petitioner under Section 148 of the Income Tax Act, 1961, was quashed, along with any consequential proceedings. The reasoning was solely based on the agreement between the petitioner and the revenue to follow the precedent set in the Jyoti Sareen case. The ratio decidendi is that where parties agree to extend the benefit of a prior judgment to a subsequent case with similar facts and legal issues, the court will grant such relief. All pending miscellaneous applications were also disposed of.

The High 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 petition was allowed, and the impugned notice dated 24.03.2026 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 by the learned counsel for both parties. The ratio decidendi is that if parties agree to a precedent being applied, the court will follow that precedent. 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. Consequently, the impugned notice dated 31.03.2024 issued to the petitioner under Section 148 of the Income Tax Act, 1961, and all consequential proceedings were quashed. The reasoning for this decision was the mutual 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 judicial pronouncement, the court will grant that relief. Any pending miscellaneous applications were also disposed of.

The High Court, in light of the consensus reached between the parties, allowed the petition. The Court quashed the impugned notices dated 12.01.2024 and 03.06.2024 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 precedent set in Jyoti Sareen’s case. The operative direction was the quashing of the notices and consequential proceedings. No issue was expressly left undecided.

The High Court held that the impugned order dated 15.01.2026, passed by the Principal Commissioner of Income Tax, Jalandhar, was indeed violative of the principles of natural justice and contrary to the specific directions issued by the Court in its order dated 04.11.2025. The Court noted that while the earlier order directed the determination of the refund after granting an opportunity of hearing, the subsequent order was passed without providing such an opportunity to the petitioner. Consequently, the Court set aside the impugned order dated 15.01.2026. The matter was remitted back to the Principal Commissioner of Income Tax, Jalandhar, to decide the issue afresh in terms of the directions issued by the High Court in its order dated 04.11.2025, ensuring that the needful is done within three months from the receipt of the copy of the present order.

The High Court, in light of a consensus between the parties and following the precedent set in Jyoti Sareen's case (supra), allowed the petition. The Court quashed the impugned notice dated 28.07.2022 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 to grant the petitioner the same relief as in the cited case. The principle established is that where a similar issue has been decided favorably for the assessee and the revenue consents, similar relief can be extended. The operative direction was the quashing of the notice and proceedings.

The High Court, in light of the consensus between the parties and following the precedent set in Jyoti Sareen's case (supra), allowed the petition. The Court quashed the impugned notice 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 parties to extend the relief granted in the cited case. The operative direction was to quash the notice and proceedings. 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 (CWP-15791-2024). Based on the consensus between the parties, the petition was allowed. The impugned notice dated 21.08.2024, issued to the petitioner under Section 148 of the Income Tax Act, 1961, was quashed. Furthermore, all consequential proceedings, if any, arising from the said notice were also quashed. The ratio decidendi is that where parties agree and a relevant precedent exists, the court will grant similar relief to maintain consistency and fairness. The court did not leave any issue undecided.

The High Court held that, in light of the consensus reached between the learned counsel for the parties, the petitioner would be entitled to the same relief as has been granted in CWP-15791-2024 – Jyoti Sareen vs. Union of India, decided on 10.09.2026. The court allowed the petition, resulting in the quashing of the impugned notice dated 31.03.2023 issued to the petitioner under Section 148 of the Income Tax Act, 1961, along with consequential proceedings, if any. The ratio decidendi is that where parties agree to parity with a previous judgment, the court will grant the same relief to avoid multiplicity of litigation and ensure consistency, provided the facts and circumstances are analogous or the parties consent to such an approach.

The High Court, in light of the consent of the parties and following the precedent set in Jyoti Sareen vs. Union of India and others (CWP-15791-2024), allowed the petition. The Court quashed the impugned notice dated 29.03.2023 issued to the petitioner under Section 148 of the Income Tax Act, 1961, and any consequential assessment proceedings. The reasoning was based on the agreement between the parties and the prior judgment. The ratio decidendi is that where parties consent and a clear precedent exists for similar relief concerning a Section 148 notice and consequential proceedings, the court should grant that relief. Any pending applications related to the matter were also to stand disposed of.

The High Court, in agreement with both parties, allowed the petition. The 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). Consequently, the impugned notice dated 10.04.2024 issued to the petitioner under Section 148 of the Income Tax Act, 1961, and any consequential proceedings were quashed. The ratio decidendi is that where parties consent and rely on a previous binding precedent of the same court, the court will extend the same relief to the present petitioner. The operative direction was the quashing of the notice and consequential proceedings.

The High Court held that in light of the consensus between the parties and following the precedent set in the case of Jyoti Sareen vs. Union of India and others (CWP-15791-2024, decided on 10.09.2026), the petition should be allowed. The Court found that the petitioner would be entitled to the same relief as granted in the Jyoti Sareen case. Consequently, the impugned notice dated 19.05.2025 issued to the petitioner under Section 148 of the Income Tax Act, 1961, and any consequential proceedings were quashed. The Court did not explicitly leave any issue undecided.

The High Court of Punjab and Haryana held that the petition is allowed in terms of the judgment in Jyoti Sareen's case (supra), dated 10.09.2026. The Court found that both parties had agreed to the same relief as granted in the precedent case. Consequently, the impugned notice dated 22.03.2024 issued to the petitioner under Section 148 of the Income Tax Act, 1961, and all consequential proceedings were quashed. The ratio decidendi is that where parties agree to the same relief as granted in a prior binding precedent, the court should follow that precedent to dispose of the current matter. The operative direction was to quash the notice and proceedings.

The High Court held that the petitioner would be entitled to the same relief as had been granted in the judgment dated 10.09.2026 passed in CWP-15791-2024 (Jyoti Sareen vs. Union of India and others). Based on this consensus between the parties, the petition was allowed. The impugned notice dated 29.03.2025, issued to the petitioner under Section 148 of the Income Tax Act, 1961, was quashed, along with any consequential proceedings that may have arisen therefrom. The reasoning is based on the agreement of both parties to follow the precedent set in the Jyoti Sareen case. The ratio decidendi is that where parties agree to parity with a prior judgment on similar facts and issues, the court will grant the same relief. No issue was expressly left undecided.

The High Court, in terms of a previous judgment in Jyoti Sareen's case (CWP-15791-2024), allowed the petition based on a consensus between the parties. The court quashed the impugned notice dated 31.03.2024 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 and the precedent set in the Jyoti Sareen case. The operative direction was to quash the notice and proceedings.

The High Court of Punjab and Haryana, in light of the consensus between the parties and following its previous decision in CWP-15791-2024 (Jyoti Sareen vs. Union of India and others) dated 10.09.2026, allowed the petition. The court quashed the impugned notice dated 08.04.2024 issued to the petitioner under Section 148 of the Income Tax Act, 1961, and any consequential proceedings. The reasoning is based on the mutual agreement of the parties to abide by the outcome of the Jyoti Sareen case, implying that the facts and legal grounds in the present case were similar enough to warrant the same relief. The ratio decidendi is that where parties agree to a specific outcome based on a prior binding precedent, the court will grant that relief.

The High Court, in light of the consensus between the parties and following the precedent set in Jyoti Sareen's case, allowed the petition. The Court quashed the impugned notice dated 30.08.2024 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 learned counsel for the parties and the prior judgment in Jyoti Sareen's case, which presumably dealt with similar grounds for challenging the reassessment notice. The operative direction was to quash the notice and proceedings. No issue was expressly left undecided.

The High Court held that in light of the consensus between the parties and following the precedent set in the case of Jyoti Sareen (CWP-15791-2024), the petition should be allowed. The court quashed the impugned notice 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 to grant the same relief as previously awarded in a similar writ petition. The ratio decidendi is that where parties consent and a clear precedent exists for similar relief, the court should grant that relief to avoid multiplicity of litigation and ensure consistency. No issues were expressly left undecided.

The High Court, in light of the consensus between the parties and following the precedent set in the case of Jyoti Sareen vs. Union of India (CWP-15791-2024), allowed the petition. The Court quashed the impugned notice issued to the petitioner under Section 148 of the Income Tax Act, 1961, and any consequential assessment proceedings. The ratio decidendi is that where parties agree to a consent order based on a prior judgment, the court will extend the same relief to maintain consistency and fairness. The operative direction was the quashing of the reassessment proceedings. No issues were expressly left undecided.

The High Court held that the petitioner (assessee) would be entitled to the same relief as granted in the judgment of Jyoti Sareen vs. Union of India and others, dated 10.09.2026. Following this consensus and the precedent set in the Jyoti Sareen case, the Court allowed the petition. The impugned notice issued to the petitioner under Section 148 of the Income Tax Act, 1961, along with any consequential proceedings, were quashed. The Court's decision was based on the agreement of the parties and the prior ruling, without delving into the merits of the specific case beyond the established precedent. No specific amount in dispute was recorded. No issue was expressly left undecided.

The High Court held that, in light of the consensus between the learned counsel for the parties and following the precedent set in Jyoti Sareen vs. Union of India and others (CWP-15791-2024), the petitioner would be entitled to the same relief. The court found that the petition was allowed in terms of the prior judgment. Consequently, the impugned notice dated 06.04.2023 issued to the petitioner under Section 148 of the Income Tax Act, 1961, and any consequential proceedings were quashed. The ratio of this decision is that where parties agree to follow a binding precedent, and the facts are analogous, the court will grant similar relief to uphold consistency and judicial economy. No issues were expressly left undecided.

The High Court, in light of the consensus between the parties and following the precedent set in Jyoti Sareen's case, allowed the petition. The court quashed the impugned notice dated 25.04.2024 issued to the petitioner under Section 148 of the Income Tax Act, 1961, and any consequential proceedings. The ratio decidendi is that where parties agree to follow a previous judgment granting similar relief, the court will extend that relief. The operative direction was the quashing of the notice and proceedings. No issues were expressly left undecided.

The High Court allowed the petitioner's request to withdraw the writ petition. The court noted that the petitioner had filed CWP No. 19465 of 2026, which was allowed on 10.09.2026, and based on this, sought permission to withdraw the present petition. The court granted this permission. The operative direction was to dismiss the petition as withdrawn. No specific findings on merits were made, as the case was disposed of on the petitioner's request for withdrawal.