IN THE HIGH COURT OF PUNJAB & HARYANA AT CHANDIGARH CWP-4973-2022 Date of Decision: 18.04.2026 SUREKHA SINGLA ... Petitioner Versus PR. COMMISSIONER OF INCOME TAX AND OTHERS ... Respondents CORAM : HON'BLE MR. JUSTICE DEEPAK SIBAL HON'BLE MS. JUSTICE LAPITA BANERJI Present : Mr. Abhishek Sharma, Advocate for Mr. Vishal Gupta, Advocate, for the petitioner. Ms. Urvashi Dhugga, Senior Standing Counsel, with Mr. Vaibhav Gupta, Junior Standing Counsel, and Ms. Kavita, Advocate, for the Income Tax Department. * * * * * 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 Union of India & Ors. 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 in question, 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. DEEPAK SIBAL JUDGE LAPITA BANERJI JUDGE 18.04.2026 Rajender Whether speaking/reasoned : Yes / No Whether reportable : Yes / No RAJENDER KUMAR 2026.04.23 19:21 I attest to the accuracy and authenticity of this order