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2025 DAILYLAW 73673 (PNJ)

SANAT ENTERPRISES PRIVATE LIMITED v. ASSISTANT COMMISSIONER OF INCOME TAX, CIRCLE 1(1), CHANDIGARH AND OTHERS

CWP/18187/2025 · 2025-07-07

Deepak Sibal, Lapita Banerji

body2025

Judgment text

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CWP-18187- IN THE HIGH COURT OF PUNJAB AND HARYANA AT Sanat Enterprises Private Limited Assistant Commissioner of Income Tax Circle 1(1), Chandigarh and others CORAM : HON’BLE MR. JUSTICE HON’BLE MS. JUSTICE LAPITA BANERJI Present : Mr. for the petitioner Mr. Yogesh Mr. Vaibhav Gupta, for the Income Tax Department DEEPAK SIBAL Challenge made through the instant petition is to the notice dated 09.06.2025 under Section 148 of the Income Tax Act, 1961. The primary ground of challenge raised by the petitioner is that the imp issued by the Jurisdictional Assessing Officer which could done because in terms of the notification issued by the notice could hav 2. In support of his afore submission, learned counsel for the petitioner places reliance on the following two judgments of this Court: i. CWP India and -2025 (O&M) Sr. No.126 IN THE HIGH COURT OF PUNJAB AND HARYANA AT CHANDIGARH CWP-18187 Date of Decision : Sanat Enterprises Private Limited Versus Assistant Commissioner of Income Tax Circle 1(1), Chandigarh HON’BLE MR. JUSTICE DEEPAK SIBAL HON’BLE MS. JUSTICE LAPITA BANERJI Mr. Nikhil Goyal Advocate for the petitioner. Mr. Yogesh Putney, Senior Standing Counsel and Mr. Vaibhav Gupta, Jr. Standing Counsel for the Income Tax Department-respondents. *** DEEPAK SIBAL, J. (Oral) Challenge made through the instant petition is to the notice .2025 (Annexure P-4) issued to the petitioner by the respondents under Section 148 of the Income Tax Act, 1961. The primary ground of challenge raised by the petitioner is that the imp issued by the Jurisdictional Assessing Officer which could done because in terms of the notification dated 29.03.2022 (Annexure P issued by the Ministry of Finance, Government of India, the impugned ould have been issued only by way of faceless assessment. In support of his afore submission, learned counsel for the petitioner places reliance on the following two judgments of this Court: CWP-15745-2024, titled Jatinder Singh Bhangu India and others, decided on 19.07.2024; and IN THE HIGH COURT OF PUNJAB AND HARYANA AT CHANDIGARH 18187-2025 (O&M) Date of Decision : 07.07.2025 …Petitioner Assistant Commissioner of Income Tax Circle 1(1), Chandigarh …Respondents DEEPAK SIBAL HON’BLE MS. JUSTICE LAPITA BANERJI Putney, Senior Standing Counsel and Jr. Standing Counsel respondents. Challenge made through the instant petition is to the notice ) issued to the petitioner by the respondents under Section 148 of the Income Tax Act, 1961. The primary ground of challenge raised by the petitioner is that the impugned notice has been issued by the Jurisdictional Assessing Officer which could have not been dated 29.03.2022 (Annexure P-5), Ministry of Finance, Government of India, the impugned e been issued only by way of faceless assessment. In support of his afore submission, learned counsel for the petitioner places reliance on the following two judgments of this Court:- Jatinder Singh Bhangu Vs. Union of decided on 19.07.2024; and Assistant Commissioner of Income Tax Circle 1(1), Chandigarh VANDANA 2025.07.09 09:36 I attest to the accuracy and integrity of this document CWP-18187- ii. CWP others 3. Learned counsel for the respondents does not dispute the fact that the case of the petitioner through the aforesaid two judgments rendered by two different co Benches of this Court in 4. In the light of the above, in terms of the law laid down in Jatinder Singh dated 09.06.2025 Officer, is hereby quashed with liberty to the respondents to proceed against the petitioner in accordance with law. 5. The July 07, 2025 vandana Whether speaking/reasoned : Whether reportable -2025 (O&M) CWP-21509-2023, titled Jasjit Singh others, decided on 29.07.2024. Learned counsel for the respondents does not dispute the fact that the case of the petitioner is covered in his through the aforesaid two judgments rendered by two different co Benches of this Court in Jatinder Singh Bhangu In the light of the above, in terms of the law laid down in Jatinder Singh Bhangu and Jasjit Singh (supra) 2025 (Annexure P-4), issued by the Officer, is hereby quashed with liberty to the respondents to proceed against the petitioner in accordance with law. The petition is allowed in the above terms. (DEEPAK SIBAL JUDGE (LAPITA BANERJI) JUDGE 5 ther speaking/reasoned : Yes/No Whether reportable : Yes/No Jasjit Singh Vs. Union of India and Learned counsel for the respondents does not dispute the fact is covered in his favour by the law laid down through the aforesaid two judgments rendered by two different co-ordinate Jatinder Singh Bhangu and Jasjit Singh (supra). In the light of the above, in terms of the law laid down in (supra), the impugned notice ), issued by the Jurisdictional Assessing Officer, is hereby quashed with liberty to the respondents to proceed against petition is allowed in the above terms. DEEPAK SIBAL) JUDGE (LAPITA BANERJI) JUDGE VANDANA 2025.07.09 09:36 I attest to the accuracy and integrity of this document