Dismissed

M/S S N Realtors Private Limited v. Deputy Commissioner of Income Tax Central Circle I and Others

Punjab & Haryana HC14 Sept 2026CWP/15888/2025

Case brief

AI extract

What is this about?

The High Court disposed of the writ petition challenging a Section 148 notice issued under the Income Tax Act for AY 2021-2022 by following the precedent of coordinate bench decisions Jatinder Singh Bhangu and Jasjit Singh.

What did the court decide?

The writ petition and pending applications were disposed of in terms of the coordinate bench judgments Jatinder Singh Bhangu and Jasjit Singh.

M/S S N Realtors Private Limit… — Constitutional and Fundamental Rights | Punjab & Haryana HC (2026)

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CWP-15888-2025

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IN THE HIGH COURT OF PUNJAB AND HARYANA AT CHANDIGARH

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216 CWP-15888-2025 (O&M) Date of Decision:-28.05.2025

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M/s S N Realtors Private Limited

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....Petitioner

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Vs.

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Dy. Commissioner of Income Tax Central Circle I, Gurugram & ors.

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...Respondents

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CORAM: HON'BLE MRS. JUSTICE LISA GILL HON'BLE MRS. JUSTICE SUDEEPTI SHARMA

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Present: Mr. Chetan Mittal, Sr. Advocate with Mr. Rishabh Kapoor, Mr. Puneet Aggarwal, Mr. Yuvraj Singh, Mr. Himanshu Gupta, Advocates for the petitioner.

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Mr. Vaibhav Gupta, Standing counsel for the respondents.

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SUDEEPTI SHARMA, J.

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Challenge in the present petition is to notice dated 21.03.2023 issued under Section 148 of the Income Tax Act, 1961 (for short ‘Act 1961”) and all consequential actions, for AY 2021-2022.

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Learned counsel for the petitioner contends that the issue involved in the present writ petition is covered by the judgment passed by a Co-ordinate Bench of this Court in the cases of Jatinder Singh Bhangu vs. Union of India and others , passed in CWP No. 15745-2024 and connected matter, decided on 19.07.2024 and Jasjit Singh vs. Union of India and others (CWP No. 215092023 and other connected matters), decided on 29.07.2024.

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Learned counsel appearing for Union of India has also not disputed the same.

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We have heard learned counsel for the parties and perused the whole records of the case.

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Sonia Arora 2025.05.31 16:09 I agree to specified portions of this document

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CWP-15888-2025

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The petitioner has challenged the notice dated 21.03.2023 issued under Section 148 of the Act, 1961 and all consequential actions, for AY 2021-2022 on the ground that the Issuing Authority had no jurisdiction to issue the same, in view of the circular/notification dated 29.03.2022 of the CBDT, wherein, it has been specifically enumerated that the NFAC has exclusive power to issue the notice under Section 148 of the Act, 1961.

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A Co-ordinate Bench of this Court in Jatinder Singh Bhangu’s case (supra) and Jasjit Singh’s case (supra), allowed the writ petitions on the same issue, as raised in the present writ petition, by granting liberty to the revenue to follow the procedure as laid down under the Act, 1961 and proceed accordingly, if so advised.

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In view of the above, the present writ petition is disposed of, in terms of Jatinder Singh Bhangu’s case (supra), decided on 19.07.2024 and Jasjit Singh’s case (supra), decided on 29.07.2024.

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