Authority: High Court of Punjab and Haryana at Chandigarh

Order Date: 28.05.2025

Case Overview

  • Petitioner: M/s Manoj Trading Co.; Respondents: National Faceless Assessment Centre (NFAC) and others.
  • The writ petition (CWP‑15759‑2025 (O&M)) challenged a notice dated 01.04.2022 issued under Section 148 of the Income Tax Act, 1961, and the assessment order dated 06.02.2024 for Assessment Year 2018‑2019, alleging that NFAC lacked jurisdiction per CBDT circular dated 29.03.2022 which reserves Section 148 notice power exclusively to NFAC.
  • Counsel for the petitioner argued that the issue was already decided in two coordinate bench judgments: Jatinder Singh Bhangu vs. Union of India (CWP No. 15745‑2024, decided 19.07.2024) and Jasjit Singh vs. Union of India (CWP No. 21509‑2023, decided 29.07.2024). The Union of India did not dispute the reliance on these precedents.
  • The Court examined the records, noted that the earlier judgments allowed the revenue to follow the procedure laid down under the Act, and therefore found no merit in the petition.

Final Outcome

  • The writ petition is disposed of in accordance with the judgments in Jatinder Singh Bhangu and Jasjit Singh.
  • All pending applications, if any, in the present matter are also ordered disposed of.

Topics: Taxation, Judicial Decision, Income Tax Assessment