201(110) IN THE HIGH COURT OF PUNJAB AND HARYANA AT Girdhari Lal Union of India and another CORAM : HON’BLE MR. JUSTICE HON’BLE MS. JUSTICE LAPITA BANERJI Present : Mr. for the petitioner. Mr. Varun Issar, Sr. Standing Counsel 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 31.03.2021, dispatched assessment year (for short-the Act) be treated as notice under Section 148 A(b) of the Act. 2. The above concession petitioner. Accordingly, the present petition is disposed of with a direction to the respondent terms of the procedure laid down under Section 148 A(b) of the Act. 3. Needless to add that in the petitioner shall be at liberty to raise all possible pleas/defences that may be available to him, in accordance with law. April 18, 2026 vandana Whether speaking/reasoned : Whether reportable IN THE HIGH COURT OF PUNJAB AND HARYANA AT CHANDIGARH CWP-4237 Date of Decision : Versus India and another HON’BLE MR. JUSTICE DEEPAK SIBAL HON’BLE MS. JUSTICE LAPITA BANERJI Mr. Tarang Goyal, Advocate for the petitioner. Mr. Varun Issar, Sr. 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 31.03.2021, dispatched to the petitioner on or after 01.04.2021, for the assessment year 2015-16, under Section 148 of the Income Tax Act, 1961 the Act) be treated as notice under Section 148 A(b) of the Act. The above concession satisfie petitioner. Accordingly, the present petition is disposed of with a direction to the respondent-revenue to proceed from the stage of the afore notice in terms of 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 available to him, in accordance with law. (DEEPAK SIBAL JUDGE (LAPITA BANERJI) JUDGE , 2026 ther speaking/reasoned : Yes/No Whether reportable : Yes/No IN THE HIGH COURT OF PUNJAB AND HARYANA AT CHANDIGARH 4237-2022 (O&M) Date of Decision : 18.04.2026 …Petitioner …Respondents DEEPAK SIBAL HON’BLE MS. JUSTICE LAPITA BANERJI Mr. Varun Issar, Sr. 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 notice dated to the petitioner on or after 01.04.2021, for the , under Section 148 of the Income Tax Act, 1961 the Act) be treated as notice under Section 148 A(b) of the Act. atisfies learned counsel for the petitioner. Accordingly, the present petition is disposed of with a direction revenue to proceed from the stage of the afore notice in terms of the procedure laid down under Section 148 A(b) of the Act. course 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