IN THE HIGH COURT OF PUNJAB & HARYANA AT CHANDIGARH Sr. No. 201(120) CWP-4500-2022 Date of decision : 18.04.2026 Hanuman Parsad Saraf .…. Petitioner Versus Union of India and another ..... Respondents CORAM : HON'BLE MR. JUSTICE DEEPAK SIBAL HON'BLE MS. JUSTICE LAPITA BANERJI Present : Mr. Sandeep Goyal, Senior Advocate, with Mr. Aditya Gupta, Advocate, Mr. Anirudh Garg, Advocate, and Mr. Mohit Bassi, Advocate, for the petitioner. Ms. Gauri Neo Rampal, Senior Standing Counsel, for the revenue. * * * * * 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 dated 31.03.2021 and 06.04.2021, 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 him, in accordance with law. [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