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2025 DAILYLAW 87440 (PNJ)

HUDSON INSURANCE BROKERS PRIVATE LIMITED v. INCOME TAX OFFICER AND OTHERS

CWP/22534/2025 · 2025-08-05

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Judgment text

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[127] Hudson Insurance Brokers Private Limited Income Tax Officer and others Coram : Present: DEEPAK SIBAL [1] dated 29.03.2025 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 not have been done because in terms of t by the Ministry of Finance, could have been issued only by way of faceless assessment. [2] petitioner places reliance on the following two judgments of this Court : IN THE HIGH COURT OF PUNJAB AND HARYANA AT CHANDIGARH CWP-22534 Date of Decision : Hudson Insurance Brokers Private Limited versus Income Tax Officer and others HON’BLE MR. JUSTICE DEEPAK SIBAL HON’BLE MR. JUSTICE SUBHAS MEHLA Mr. B.M. Monga, Advocate and Mr. Rohit Kaura, for the petitioner. Mr. Yogesh Putney, Senior Standing Counsel, Mr. Vidul Kapoor, Junior Standing Counsel Junior Standing Counsel for the respondents Department. *** DEEPAK SIBAL, J. (ORAL) Challenge made through the instant petition is to the notice 9.03.2025 (Annexure P-1) issued to the petitioner by 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 not have been done because in terms of the notification dated 29.03.2022 (Annexure P by the Ministry of Finance, Department of Revenue have been issued only by way of faceless assessment. In support of his afore submission, learned counsel for the etitioner places reliance on the following two judgments of this Court : (i) CWP No.15745 of 2024 Vs. Union of India and others, decided on IN THE HIGH COURT OF PUNJAB AND HARYANA AT CHANDIGARH 22534-2025 Date of Decision : 05.08.2025 Hudson Insurance Brokers Private Limited …Petitioner ….Respondents DEEPAK SIBAL SUBHAS MEHLA and Mr. Rohit Kaura, Advocate Mr. Yogesh Putney, Senior Standing Counsel, Mr. Vidul Kapoor, Junior Standing Counsel and Mr. Vaibhav Gupta, for the respondents-Income Tax Challenge made through the instant petition is to the notice ) issued to the petitioner by the respondent 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 not have been done he notification dated 29.03.2022 (Annexure P-2), issued Department of Revenue, the impugned notice have been issued only by way of faceless assessment. In support of his afore submission, learned counsel for the etitioner places reliance on the following two judgments of this Court :- CWP No.15745 of 2024 - Jatinder Singh Bhangu Vs. Union of India and others, decided on 19.07.2024. Challenge made through the instant petition is to the notice 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 not have been done ), issued , the impugned notice In support of his afore submission, learned counsel for the 19.07.2024. RAJNEESH SHARMA 2025.08.05 20:05 I attest to the accuracy and integrity of this document CWP-22534-2025 -2- (ii) CWP No.21509 of 2023 - Jasjit Singh Vs. Union of India and others, decided on 29.07.2024. [3] Learned counsel for the respondents-Income Tax Department does not dispute the fact that the case of the petitioner is covered in his favour by the law laid down through the aforesaid two judgments rendered by two different Co-ordinate Benches of this Court in Jatinder Singh Bhangu’s and Jasjit Singh’s cases (supra). [4] In the light of the above, in terms of the law laid down in Jatinder Singh Bhangu’s and Jasjit Singh’s cases (supra), the impugned notice dated 29.03.2025 (Annexure P-1) issued by the Jurisdictional Assessing Officer, is hereby quashed with liberty to the respondents to proceed against the petitioner in accordance with law. [5] The petition is allowed in the above terms. (DEEPAK SIBAL) JUDGE (SUBHAS MEHLA) JUDGE 05.08.2025 ‘R. Sharma' Whether speaking/ reasoned : Yes/No Whether reportable : Yes/No RAJNEESH SHARMA 2025.08.05 20:05 I attest to the accuracy and integrity of this document