IN THE HIGH COURT OF PUNJAB AND 127 MANISH GUPTA ASSISTANT COMMISSIONER OF INCOME TAX AND OTHERS CORAM: HON’BLE MR. JUSTICE ANUPINDER SINGH GREWAL HON’BLE MR. JUSTICE DEEPAK MANCHANDA Present: Mr. Mr. Ubhai Bharti Gupta, Advocate Ms. Mamta Gupta, Advocate and Ms. Uma Bharti, Advocate Mr. Yogesh Putney, Senior Standing counsel, Mr. Vi Mr. Vaibhav Gupta, Advocate, Junior Standing counsel for Income Tax. ANUPINDER SINGH GREWAL, J. (ORAL) The petitioner has challenged the notice dated (Annexure P-1) issued by respondent N Act, 1961 (hereinafter referred to as the ‘Act, 1961’) and all consequential assessment proceedings for Assessment Year 202 2. Learned counsel for the petitioner submits that the impugned notice under Section 148 of the Act, 1961 has erroneously been issued by the Jurisdictional Assessing Officer although he has no jurisdiction to issue the same in view of the Notification dated 28/29.03.2022 which provides for faceless assessment proceedings and exclusive powers to issue notice under Section 148 of the Act, 1961. He further submits that the coordinate Bench of this Court in CWP No.15745 Jatinder Singh Bhangu IN THE HIGH COURT OF PUNJAB AND HARYANA AT CHANDIGARH CWP-19535-2025 DATE OF DECISION: 15.07.2025 MANISH GUPTA Versus ASSISTANT COMMISSIONER OF INCOME TAX AND OTHERS HON’BLE MR. JUSTICE ANUPINDER SINGH GREWAL HON’BLE MR. JUSTICE DEEPAK MANCHANDA Mr. Vishav Bharti Gupta, Advocate Mr. Ubhai Bharti Gupta, Advocate Ms. Mamta Gupta, Advocate and Ms. Uma Bharti, Advocate for the petitioner. Mr. Yogesh Putney, Senior Standing counsel, Mr. Vidul Kapoor, Advocate, Junior Standing counsel Mr. Vaibhav Gupta, Advocate, Junior Standing counsel for Income Tax. ANUPINDER SINGH GREWAL, J. (ORAL) The petitioner has challenged the notice dated 1) issued by respondent No.1 under Section 148 of the Income Tax Act, 1961 (hereinafter referred to as the ‘Act, 1961’) and all consequential assessment proceedings for Assessment Year 202 Learned counsel for the petitioner submits that the impugned notice n 148 of the Act, 1961 has erroneously been issued by the Jurisdictional Assessing Officer although he has no jurisdiction to issue the same in view of the Notification dated 28/29.03.2022 which provides for faceless assessment proceedings and National Faceless Assessment Centre (NFAC) exclusive powers to issue notice under Section 148 of the Act, 1961. He further submits that the coordinate Bench of this Court in CWP No.15745 Jatinder Singh Bhangu Vs. Union of India and others HARYANA AT CHANDIGARH 2025 DATE OF DECISION: 15.07.2025 … Petitioner (s) ASSISTANT COMMISSIONER OF INCOME TAX AND OTHERS ... Respondent(s) HON’BLE MR. JUSTICE ANUPINDER SINGH GREWAL HON’BLE MR. JUSTICE DEEPAK MANCHANDA , Advocate for the petitioner. Mr. Yogesh Putney, Senior Standing counsel, dul Kapoor, Advocate, Junior Standing counsel Mr. Vaibhav Gupta, Advocate, Junior Standing counsel The petitioner has challenged the notice dated 30.03.2025 o.1 under Section 148 of the Income Tax Act, 1961 (hereinafter referred to as the ‘Act, 1961’) and all consequential assessment proceedings for Assessment Year 2020-2021. Learned counsel for the petitioner submits that the impugned notice n 148 of the Act, 1961 has erroneously been issued by the Jurisdictional Assessing Officer although he has no jurisdiction to issue the same in view of the Notification dated 28/29.03.2022 which provides for faceless eless Assessment Centre (NFAC) has exclusive powers to issue notice under Section 148 of the Act, 1961. He further submits that the coordinate Bench of this Court in CWP No.15745-2024 - Vs. Union of India and others and connected matter, .03.2025 o.1 under Section 148 of the Income Tax Act, 1961 (hereinafter referred to as the ‘Act, 1961’) and all consequential Learned counsel for the petitioner submits that the impugned notice n 148 of the Act, 1961 has erroneously been issued by the Jurisdictional Assessing Officer although he has no jurisdiction to issue the same in view of the Notification dated 28/29.03.2022 which provides for faceless has exclusive powers to issue notice under Section 148 of the Act, 1961. He further - SWARNJIT SINGH 2025.07.15 16:29 I attest to the accuracy and integrity of this document CWP-19535-2025 decided on 19.07.2024 as well as CWP No.21509 of India and others allowed the writ petitions involving similar issue and liberty had b the respondents therein to follow the procedure laid down under the Act, 1961 and proceed accordingly, if so advised. 3. Therefore, the petition is disposed of in the same terms as the judgment in the case of (supra) and Jasjit Singh Vs. Union of India and others (supra). Pending application(s), if any, also stands disposed of. 15.07.2025 SwarnjitS Whether speaking/reasoned Whether reportable 2025 decided on 19.07.2024 as well as CWP No.21509 of India and others and other connected matters, decided on 29.07.2024, had allowed the writ petitions involving similar issue and liberty had b the respondents therein to follow the procedure laid down under the Act, 1961 and proceed accordingly, if so advised. Therefore, the petition is disposed of in the same terms as the judgment in the case of Jatinder Singh Bhangu Jasjit Singh Vs. Union of India and others (supra). Pending application(s), if any, also stands disposed of. (ANUPINDER SINGH GREWAL) (DEEPAK MANCHANDA) Whether speaking/reasoned : Yes / No Whether reportable : Yes / No -2- decided on 19.07.2024 as well as CWP No.21509-2023-Jasjit Singh Vs. Union and other connected matters, decided on 29.07.2024, had allowed the writ petitions involving similar issue and liberty had been granted to the respondents therein to follow the procedure laid down under the Act, 1961 Therefore, the petition is disposed of in the same terms as the Vs. Union of India and others Jasjit Singh Vs. Union of India and others (supra). Pending application(s), if any, also stands disposed of. (ANUPINDER SINGH GREWAL) JUDGE (DEEPAK MANCHANDA) JUDGE Yes / No Yes / No Jasjit Singh Vs. Union and other connected matters, decided on 29.07.2024, had een granted to the respondents therein to follow the procedure laid down under the Act, 1961 Therefore, the petition is disposed of in the same terms as the n of India and others SWARNJIT SINGH 2025.07.15 16:29 I attest to the accuracy and integrity of this document