IN THE HIGH COURT OF PUNJAB & HARYANA AT CHANDIGARH Sr. No. 201(111) CWP-4341-2022 (O&M) Date of decision : 18.04.2026 Loil Continental Foods Ltd. .…. Petitioner Versus Deputy Commissioner of Income Tax, Central Circle-3, Ludhiana and another ..... Respondents CORAM : HON'BLE MR. JUSTICE DEEPAK SIBAL HON'BLE MS. JUSTICE LAPITA BANERJI Present : Ms. Radhika Suri, Senior Advocate, with Mr. Abhinav Narang, Advocate, and Ms. Parnika Singla, 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 notice dated 31.03.2021, dispatched to the petitioner on or after 01.04.2021, for the assessment year 2013-14, under Section 148 of the Income Tax Act, 1961 (for short-the Act) be treated as notice 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 notice, 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