Justice Sanjay Vashisht

Recent court decisions from the Punjab & Haryana High Court are reinforcing the primacy of statutory tax law over administrative circulars, impacting several entities including Innovative Infracity, Sameer Dalmia HUF, Maharaja Aggarsain Udyog, and Bansal Rice. The court consistently quashed income tax notices issued under Section 148, citing a lack of jurisdiction and non-compliance with faceless assessment procedures, referencing prior rulings in the Jasjit Singh and Jatinder Singh Bhangu cases. This trend suggests a heightened scrutiny of the revenue department's assessment practices and could lead to a reassessment of pending tax notices, potentially creating uncertainty for businesses while strengthening taxpayer rights and challenging the government’s ability to aggressively pursue tax collection through circular interpretations.