Authority: High Court of Punjab and Haryana at Chandigarh
Order Date: 25.04.2025
Case Overview
- Petitioner: Ravinder Singh Sidhu HUF
- Respondents: Income Tax Officer, Ward 3, Khanna & others
- Case Number: CWP-11310-2025 (O&M)
- Nature of Proceeding: Writ petition challenging tax notices and assessment for Assessment Year 2022‑2023.
- Key Dates & Documents Challenged:
- Notice dated 26.03.2024 issued under Section 148 of the Income Tax Act, 1961.
- Assessment order dated 28.03.2025 issued under Section 147 of the Act.
- Demand notice and penalty show‑cause notice dated 28.03.2025.
- Grounds of Challenge: Petitioner argued that the issuing authority lacked jurisdiction because the CBDT circular dated 29.03.2022 expressly reserves the power to issue Section 148 notices to the National Faceless Assessment Centre (NFAC).
- Counsel: For petitioner – Mr. Vishav Bharti Gupta and Ms. Mamta Gupta; for respondents – Sr. Standing Counsel Mr. Ranvijay Singh.
- Judicial Reasoning: The bench referred to two earlier decisions of this Court:
1. Jatinder Singh Bhangu vs. Union of India (CWP No. 15745‑2024) decided on 19.07.2024.
2. Jasjit Singh vs. Union of India (CWP No. 21509‑2023) decided on 29.07.2024.
Both precedents upheld the revenue’s procedural authority under the Act and allowed the issuance of notices as per statutory provisions.
Final Outcome
- The writ petition is disposed of in accordance with the aforementioned judgments.
- All pending applications, if any, related to the petition are also ordered disposed of.
Topics: Tax Litigation, Income Tax Assessment