Authority: High Court of Punjab and Haryana at Chandigarh

Order Date: 28 May 2025

Case Overview

  • Petitioner: M/S Bhanu Infrabuild Pvt. Ltd.
  • Respondents: Deputy Commissioner of Income Tax, Central Circle I, Gurugram and others.
  • Issue: Petition challenged a notice dated 30 March 2023 issued under Section 148 of the Income Tax Act, 1961 for Assessment Year 2016‑2017, alleging the issuing authority lacked jurisdiction because a CBDT circular dated 29 March 2022 expressly reserves exclusive power to the National Faceless Assessment Centre (NFAC) to issue such notices.
  • The petitioner relied on two earlier judgments of this Court—Jatinder Singh Bhangu v. Union of India (19 July 2024) and Jasjit Singh v. Union of India (29 July 2024)—which addressed the same jurisdictional question and granted the revenue the liberty to follow the procedure laid down in the Act.

Final Outcome

  • The Court disposed of the writ petition in accordance with the earlier judgments, holding that the revenue may proceed under Section 148 as per the statutory procedure.
  • All pending applications, if any, relating to the same notice are also ordered disposed of.

Topics: Tax Law, Section 148 Notice, Income Tax Litigation