Rudra Alloys Pvt. Ltd. Vs ACIT (Punjab And Haryana High Court)
The Punjab and Haryana High Court decided a writ petition challenging a notice dated 28.06.2025 issued under Section 148 of the Income-tax Act, 1961, along with all consequential proceedings for Assessment Year 2021-22. The petitioner contended that the issuing authority lacked jurisdiction in view of the CBDT notification/circular dated 29.03.2022, which specifically provided that the National Faceless Assessment Centre (NFAC) had the exclusive power to issue notices under Section 148 of the Act.
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The petitioner’s counsel submitted that the issue raised in the writ petition was already covered by the judgments of a Coordinate Bench of the High Court in Jatinder Singh Bhangu vs. Union of India and others, decided on 19.07.2024 in CWP No. 15745-2024 and connected matters, and Jasjit Singh vs. Union of India and others, decided on 29.07.2024 in CWP No. 21509 of 2023 and connected matters. Counsel for the respondents did not dispute that the issue was covered by those decisions.
After hearing the parties and examining the record, the High Court noted that the Coordinate Bench, in Jatinder Singh Bhangu and Jasjit Singh, had allowed the writ petitions on the same issue by granting liberty to the Revenue to follow the procedure prescribed under the Income-tax Act, 1961 and proceed in accordance with law, if so advised.
