2025:HHC:20316 IN THE HIGH COURT OF HIMACHAL PRADESH, SHIMLA. CWP No. 10393 of 2025 Date of decision: 28.06.2025 Brij Mohan Khanna …Petitioner Versus Union of India & Ors. …Respondents Coram The Hon’ble Mr. Justice Tarlok Singh Chauhan, Judge. The Hon’ble Mr. Justice Sushil Kukreja, Judge. Whether approved for reporting? No. For the Petitioner: Mr. M. R. Sharma, Advocate. For the Respondents: Mr. Harish Sharma, Senior Panel Counsel, for respondent No. 1. Mr. Neeraj Sharma and Mr. Ishaan Kashyap, Advocates, for respondents No. 2 to 4. Tarlok Singh Chauhan, Judge (Oral) Notice. Mr. Harish Sharma and Mr. Neeraj Sharma, Advocates, appear and waive service of notice on behalf of the respective respondents. 2. The instant petition has been filed for grant of the following substantive reliefs:- i) for issuance of an appropriate writ, order or direction, to the respondents, to transmit the entire records of the case to this Hon'ble Court; And For the issuance of a writ in the nature of Certiorari and/or any other appropriate writ, Order or direction quashing the Notice dated 27.03.2025 being approval (Annexure P- 4) under Section 151 of the Income Tax Act, issued by respondent No.2, Notice dated 28.03.2025 (Annexure P-5) 2025:HHC:20316 under Section 148 of the Income Tax Act, issued by respondent No.3, issued by respondent No.3. And ii) For the issuance of a writ in the nature of Certiorari and/or any other appropriate writ, Order or direction declaring the proceedings for reassessment under Section 148 of the Act and the proceedings approved by granting sanction under Section 151 of the Income Tax Act, 1961 by the Principal Commissioner of Income Tax, respondent no. 2, in the case of the petitioner, being contrary to principles of natural justice, illegal and wholly without jurisdiction; And iii) For the issuance of writ in the nature of Certiorari and/or any other appropriate writ order or direction staying the operation of the impugned Notice dated 27.03.2025 being approval (Annexure P-4) under Section 151 of the Income Tax Act, issued by respondent No.2, Notice dated 28.03.2025 (Annexure P-5) under Section 148 of the Income Tax Act, issued by respondent No.3, till the final decision of the present writ petition by this Hon'ble Court; And iv) For the issuance of writ in the nature of Certiorari and/or any other appropriate writ order or direction restraining the respondents, in particular the National Faceless Assessment Centre, respondent no. 3 and respondent no. 4 from proceeding further in the case of the petitioner under Section 144 B read with Section 143(3)/147/148 of the Income Tax, Act, 1961. 3. The subject matter of the challenge in this petition, whereby the legality, validity and propriety of impugned notice under Section 148, dated 28.03.2025 (Annexure P-5) is already under consideration before the Hon’ble Supreme Court of India in SLP (C) Diary No. 17041/2024., case titled Union of India & Ors. Vs. Association of Technical Textiles Manufacturers and Processors & Anr. 4. Since the issue involved in this petition is already pending consideration before the Hon’ble Supreme Court, 2025:HHC:20316 therefore, keeping in view the judicial discipline, we refrain ourselves from giving our opinion with respect to impugned notice under Section 148, dated 28.03.2025 (Annexure P-5), as assailed in this petition. We direct that the present petition shall be governed by the judgment passed by the Hon’ble Supreme Court and the decision thereto, shall be binding on this case also. 5. The continuity of proceedings before the competent authority, in view of the pendency of the matter before the Hon’ble Supreme Court is bound to lead to multiplicity of litigation. Therefore, we deem it appropriate to stay such proceedings till the time issue is finally decided by the Hon’ble Supreme Court. Ordered accordingly. 6. The petition is disposed of in above terms, so also the pending application(s), if any. (Tarlok Singh Chauhan) Judge (Sushil Kukreja) 28th June, 2025 Judge (sanjeev)