201(219) IN THE HIGH COURT OF PUNJAB AND HARYANA AT M/s Sai Enterprises Union of India CORAM : HON’BLE MR. JUSTICE HON’BLE MS. JUSTICE LAPITA BANERJI Present : Mr. for the petitioner. Ms for the respondents. DEEPAK SIBAL At the outset, learned counsel for the revenue concedes that in terms of the law laid down by the Supreme Court in others Vs. Ashish Agarwal 19.04.2021 and respectively, under Section 148 of the Income Tax Act, 1961 (for short Act) be treated as notice 2. The above concession Accordingly, the present petition is disposed of with a direction to the respondent-revenue to proceed from the stage of the afore notice the procedure laid down under Section 148 A(b) of the Act. 3. Needless to add that in the cou petitioner shall be at liberty to raise all possible pleas/defences that may be available to it, in accordance with law. April 18, 2026 vandana Whether speaking/reasoned : Whether reportable : IN THE HIGH COURT OF PUNJAB AND HARYANA AT CHANDIGARH CWP-26871 Date of Decision : M/s Sai Enterprises Versus and others HON’BLE MR. JUSTICE DEEPAK SIBAL HON’BLE MS. JUSTICE LAPITA BANERJI Mr. Ankit Midha, Advocate, for the petitioner. Ms. Urvashi Dhugga, Senior Standing Counsel for the respondents. *** DEEPAK SIBAL, J. (Oral) At the outset, learned counsel for the revenue concedes that in terms of the law laid down by the Supreme Court in Vs. Ashish Agarwal (2023)1 SCC 617 9.04.2021 and 09.04.2021, for the assessment year , under Section 148 of the Income Tax Act, 1961 (for short Act) be treated as notices under Section 148 A(b) of the Act. The above concession satisfies learned counsel for the pet Accordingly, the present petition is disposed of with a direction to the revenue to proceed from the stage of the afore notice the procedure laid down under Section 148 A(b) of the Act. 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 in accordance with law. (DEEPAK SIBAL JUDGE (LAPITA BANERJI) JUDGE , 2026 Whether speaking/reasoned : Yes/No Whether reportable : Yes/No IN THE HIGH COURT OF PUNJAB AND HARYANA AT CHANDIGARH 1-2021 (O&M) Date of Decision : 18.04.2026 …Petitioner …Respondents DEEPAK SIBAL HON’BLE MS. JUSTICE LAPITA BANERJI Standing Counsel, 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 7, the impugned notices dated assessment years 2013-14 and 2014-15 , under Section 148 of the Income Tax Act, 1961 (for short-the under Section 148 A(b) of the Act. learned counsel for the petitioner. Accordingly, the present petition is disposed of with a direction to the revenue to proceed from the stage of the afore notices, in terms of the procedure laid down under Section 148 A(b) of the Act. rse of the afore proceedings the petitioner shall be at liberty to raise all possible pleas/defences that may be DEEPAK SIBAL) JUDGE (LAPITA BANERJI) JUDGE VANDANA 2026.05.01 09:31 I attest to the accuracy and integrity of this document