IN THE HIGH COURT OF PUNJAB & HARYANA AT CHANDIGARH Sr. No. 201(6) CWP-14891-2021 (O&M) Date of decision : 18.04.2026 Rinji Estates Developers Pvt. Ltd. .…. Petitioner Versus The Income Tax Officer, Gurgaon and another ..... Respondents CORAM : HON'BLE MR. JUSTICE DEEPAK SIBAL HON'BLE MS. JUSTICE LAPITA BANERJI Present : Mr. Akshay Bhan, Senior Advocate, with Mr. Aman Bansal, Advocate, and Mr. Shantanu Bansal, Advocate, for the petitioner. Mr. Varun Issar, Senior Standing Counsel, for the Income Tax Department. * * * * * DEEPAK SIBAL, J. (Oral) 1. At the outset, learned counsel for the revenue concedes that in terms of the law laid down by the Supreme Court in Union of India and others vs. Ashish Agarwal (2023) 1 SCC 617, the impugned notices both dated 31.03.2021, dispatched to the petitioner on or after 01.04.2021, for the respective assessment years, under Section 148 of the Income Tax Act, 1961 (for short-the Act) be treated as notices under Section 148A(b) of the Act. 2. The above concession satisfies learned senior counsel for the petitioner. Accordingly, the present petition is disposed of with a direction to the respondent- revenue to proceed from the stage of the afore notices, in terms of the procedure laid down under Section 148A(b) of the Act. 3. Needless to add that in the course of the afore proceedings the petitioner shall be at liberty to raise all possible pleas/defences that may be available to it, in accordance with law. 4. Pending miscellaneous application(s), if any, also stand disposed of. [DEEPAK SIBAL] JUDGE 18.04.2026 [LAPITA BANERJI] shamsher JUDGE Whether speaking/reasoned : Yes / No Whether reportable : Yes / No SHAMSHER SINGH 2026.04.24 10:15 I attest to the accuracy and integrity of this document Punjab and haryana high court, chandigarh