Authority: High Court of Punjab and Haryana at Chandigarh

Order Date: 28.03.2025

Case Overview

  • Petitioner: M/s Bright Media; Respondents: Union of India and others.
  • The petition challenged a notice dated 24.01.2024 bearing DIN and letter No. ITBA/AST/S/148_1/2023-24/1060084625 issued under Section 148 of the Income Tax Act, 1961 for Assessment Year 2020‑2021.
  • Petitioner argued the issuing authority lacked jurisdiction because CBDT circular dated 29.03.2022 expressly reserves the power to issue Section 148 notices to the National Faceless Assessment Centre (NFAC).
  • The court noted that a coordinate bench had previously decided similar issues in Jatinder Singh Bhangu v. Union of India (CWP No. 15745‑2024, decided 19.07.2024) and Jasjit Singh v. Union of India (CWP No. 21509‑2023, decided 29.07.2024), granting liberty to revenue to follow the statutory procedure.

Final Outcome

  • The writ petition is disposed of in accordance with the earlier judgments, confirming that the revenue may proceed under the procedure laid down in the Act.
  • All pending applications, if any, related to the notice are also ordered disposed of.

Topics: Tax Notice Jurisdiction, Judicial Precedent