Quashed

Patna Sahib Charitable Educational Trust v. Income Tax Officer Exemptions Ward, Chandigarh and Others

Punjab & Haryana HC10 Sept 2026CWP/19150/2025

Case brief

AI extract

What is this about?

This petition challenged a notice dated 16.04.2024 issued under Section 148 of the Income Tax Act, 1961 by the Jurisdictional Assessing Officer. The Court quashed the notice relying on recent judgments holding that such notices must be issued via faceless assessment after a specific notification.

What did the court decide?

The impugned notice dated 16.04.2024 issued under Section 148 of the Income Tax Act, 1961 is quashed with liberty to the respondents to proceed against the petitioner in accordance with law.

Patna Sahib Charitable Educational Trust… — Writ and Judicial Review | Punjab & Haryana HC (2026)

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IN THE HIGH COURT OF PUNJAB & HARYANA AT CHANDIGARH

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Sr. No.108 CWP-19150-2025

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Date of decision : 11.07.2025

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Patna Sahib Charitable Educational Trust .…. Petitioner

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Versus

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Income Tax Officer Exemptions Ward, Chandigarh and others ..... Respondents

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CORAM : HON'BLE MR. JUSTICE DEEPAK SIBAL HON'BLE MS. JUSTICE LAPITA BANERJI

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Present : Mr. Kartik Bansal, Advocate, for the petitioner.

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Mr. Varun Issar, Senior Standing Counsel, with Ms. Paridhi Sandhu, Junior Standing Counsel, for the Income Tax Department.

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DEEPAK SIBAL, J . (Oral)

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Challenge made through the instant petition is to the notice dated 16.04.2024 (Annexure P-1) issued to the petitioner by the respondents under Section 148 of the Income Tax Act, 1961. The primary ground of challenge raised by the petitioner is that the impugned notice has been issued by the Jurisdictional Assessing Officer which could have not been done because in terms of the notification dated 29.03.2022 (Annexure P-2) issued by the Ministry of Finance, Government of India, the impugned notice could have been issued only by way of faceless assessment.

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In support of his afore submission, learned counsel for the petitioner places reliance on the following two judgments of this Court:-

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(i) CWP-15745-2024, titled Jatinder Singh Bhangu vs. Union

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of India and others , decided on 19.07.2024; and

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(ii) CWP-21509-2023, titled Jasjit Singh vs. Union of India and others , decided on 29.07.2024.

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Learned counsel for the respondents does not dispute the fact that the case of the petitioner is covered in its favour by the law laid down through the

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SHAMSHER SINGH 2025.07.17 10:06 I attest to the accuracy and integrity of this document Punjab and haryana high court, chandigarh

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CWP-19150-2025

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[ 2 ]

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aforesaid two judgments rendered by two different co-ordinate Benches of this Court in the cases of Jatinder Singh Bhangu and Jasjit Singh (supra).

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In the light of the above, in terms of the law laid down in the cases of Jatinder Singh Bhangu and Jasjit Singh (supra), the impugned notice dated 16.04.2024 (Annexure P-1), issued by the Jurisdictional Assessing Officer, is hereby quashed with

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liberty to the respondents to proceed against the petitioner in accordance with law.

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The petition is allowed in the above terms.

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[DEEPAK SIBAL] JUDGE

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11.07.2025 [LAPITA BANERJI] shamsher JUDGE Whether speaking/reasoned : Yes / No Whether reportable : Yes / No

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SHAMSHER SINGH 2025.07.17 10:06 I attest to the accuracy and integrity of this document Punjab and haryana high court, chandigarh

Patna Sahib Charitable Educational Trust v. Income Tax Officer Exemptions Ward, Chandigarh and Others

Case brief

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Patna Sahib Charitable Educational Trust v. Income Tax Officer Exemptions Ward, Chandigarh and Others

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