AI Insights
The case involves multiple writ petitions challenging the notices issued by the Jurisdictional Assessing Officers under Section 148 of the Income Tax Act, 1961, for re-assessment. The petitioners argued that following the introduction of the faceless assessment scheme, such notices should be issued by the National Faceless Assessment Centre rather than local officers. The court examined the statutory framework and the specific provisions of the Income Tax Act, particularly Sections 119, 120, 144B, and 151A, along with the notifications issued for faceless assessments. The court found that the procedural requirements for issuing notices under the faceless assessment scheme were not followed, leading to the quashing of the notices.
Appeal Details
Counselvise Citation
[2024] 140 COUNSELVISE.COM (IT) 813642 (HC-CHANDIGARH)
Assessee PAN
Bench
Appeal Number
CRN Number
Appellant
Respondent
Appeal Type
Others
Pronouncement Date
29-07-2024
Assessment Year
misc
Judgement Text
"IN THE HIGH COURT OF PUNJAB AND HARYANA 240.42 JASJIT SINGH V/S UNION OF INDIA AND OTHERS HARISH KUMAR V/S NATIONAL FACELESS ASSESSMENT CENTRE DELHI AND ANOTHER SHAVINDER KAUR V/S UNION OF INDIA AND OTHERS EXETER METBIZ INDIA PRIVATE LIMITED V/S UNION OF INDIA AND OTHERS IN THE HIGH COURT OF PUNJAB AND HARYANA AT CHANDIGARH CWP-21509 Reserved on 24.07.2024 Date of Decision: 29.07.2024 JASJIT SINGH UNION OF INDIA AND OTHERS CWP-9436 Reserved on HARISH KUMAR V/S NATIONAL FACELESS ASSESSMENT CENTRE DELHI AND CWP-21564 Reserved on 24.07.2024 SHAVINDER KAUR UNION OF INDIA AND OTHERS CWP-14437 Reserved on 24.07.2024 EXETER METBIZ INDIA PRIVATE LIMITED UNION OF INDIA AND OTHERS IN THE HIGH COURT OF PUNJAB AND HARYANA AT CHANDIGARH 21509-2023 (O&M) Reserved on 24.07.2024 Date of Decision: 29.07.2024 …Petitioner …Respondents 9436-2023 Reserved on 24.07.2024 …Petitioner NATIONAL FACELESS ASSESSMENT CENTRE DELHI AND …Respondents 21564-2023 (O&M) Reserved on 24.07.2024 …Petitioner …Respondents 14437-2024 (O&M) Reserved on 24.07.2024 EXETER METBIZ INDIA PRIVATE LIMITED …Petitioner …Respondents NATIONAL FACELESS ASSESSMENT CENTRE DELHI AND RAJESH KUMAR 2024.08.01 09:22 I attest to the accuracy and authenticity of this order/judgment. Punjab & Haryana High Court, Chandigarh. CWP-21509-2023 M/S JALANDHAR TRADERS V/S ASSISTANT COMMISSIONER OF INCOME TAX CIRCLE VVAA FILMS PRIVATE LIMITED V/S INCOME TAX OFFICER AND ANOTHER SIDDHARTH JAIN V/S INCOME TAX OFFICER AND OTHERS SANJAY JAIN V/S UNION OF INDIA AND OTHERS ROHIT MEHTA V/S INCOME TAX OFFICER WARD 5 1 LUDHIANA Page 2 of 46 2023 (O&M) and connected cases. CWP-15293 Reserved on 24.07.2024 M/S JALANDHAR TRADERS ASSISTANT COMMISSIONER OF INCOME TAX CIRCLE CWP-16361 Reserved on 24.07.2024 VVAA FILMS PRIVATE LIMITED INCOME TAX OFFICER AND ANOTHER CWP-16767 Reserved on 24.07.2024 SIDDHARTH JAIN INCOME TAX OFFICER AND OTHERS CWP-16941 Reserved on 24.07.2024 SANJAY JAIN UNION OF INDIA AND OTHERS CWP-17036 Reserved on 24.07.2024 ROHIT MEHTA INCOME TAX OFFICER WARD 5 1 LUDHIANA and connected cases. 15293-2024 (O&M) Reserved on 24.07.2024 …Petitioner ASSISTANT COMMISSIONER OF INCOME TAX CIRCLE-I …Respondent 16361-2024 (O&M) Reserved on 24.07.2024 …Petitioner …Respondents 16767-2024 (O&M) Reserved on 24.07.2024 …Petitioner …Respondents 16941-2024 (O&M) Reserved on 24.07.2024 …Petitioner …Respondents 17036-2024 (O&M) Reserved on 24.07.2024 …Petitioner INCOME TAX OFFICER WARD 5 1 LUDHIANA …Respondent RAJESH KUMAR 2024.08.01 09:22 I attest to the accuracy and authenticity of this order/judgment. Punjab & Haryana High Court, Chandigarh. CWP-21509-2023 NAVIN KHOSLA V/S UNION OF INDIA AND OTHERS JASBIR SINGH MAKKAR V/S UNION OF INDIA AND OTHERS MONGA RICE MILLS UNION OF INDIA AND ORS MONGA RICE MILLS UNION OF INDIA AND ORS SANDEEP SIDHU INCOME TAX OFFICER, PHAGWARA Page 3 of 46 2023 (O&M) and connected cases. CWP-17207 Reserved on 24.07.2024 NAVIN KHOSLA UNION OF INDIA AND OTHERS CWP-17210 Reserved on JASBIR SINGH MAKKAR UNION OF INDIA AND OTHERS CWP-12198 Reserved on 24.07.2024 MONGA RICE MILLS V/S UNION OF INDIA AND ORS CWP-12199 Reserved on 24.07.2024 MONGA RICE MILLS V/S UNION OF INDIA AND ORS CWP Reserved on 24.07.2024 SANDEEP SIDHU V/S INCOME TAX OFFICER, PHAGWARA and connected cases. 17207-2024 (O&M) Reserved on 24.07.2024 …Petitioner …Respondents 17210-2024 (O&M) Reserved on 24.07.2024 …Petitioner …Respondents 12198-2023 (O&M) Reserved on 24.07.2024 ...Petitioner ...Respondents 12199-2023 (O&M) Reserved on 24.07.2024 ...Petitioner ...Respondents CWP-12770-2023 (O&M) Reserved on 24.07.2024 ...Petitioner ...Respondent RAJESH KUMAR 2024.08.01 09:22 I attest to the accuracy and authenticity of this order/judgment. Punjab & Haryana High Court, Chandigarh. CWP-21509-2023 M/S KKH ENTERPRISES INCOME TAX OFFICER M/S KKH ENTERPRISES INCOME TAX OFFICER RAMESH CHANDRA VERMA UNION OF INDIA AND OTHERS B.R. FOODS UNION OF INDIA AND OTHERS MONGA RICE MILLS UNION OF INDIA AND OTHERS Page 4 of 46 2023 (O&M) and connected cases. CWP Reserved on 24.07.2024 M/S KKH ENTERPRISES V/S INCOME TAX OFFICER CWP Reserved on 24.07.2024 M/S KKH ENTERPRISES V/S INCOME TAX OFFICER CWP Reserved on 24.07.2024 RAMESH CHANDRA VERMA V/S UNION OF INDIA AND OTHERS CWP Reserved on 24.07.2024 B.R. FOODS V/S UNION OF INDIA AND OTHERS CWP Reserved on 24.07.2024 MONGA RICE MILLS V/S UNION OF INDIA AND OTHERS and connected cases. CWP-12888-2023 (O&M) Reserved on 24.07.2024 ...Petitioner ...Respondent CWP-12916-2023 (O&M) Reserved on 24.07.2024 ...Petitioner ...Respondent CWP-13869-2023(O&M) Reserved on 24.07.2024 ...Petitioner ...Respondents CWP-13870-2023(O&M) Reserved on 24.07.2024 ...Petitioner .......Respondents CWP-13871-2023(O&M) Reserved on 24.07.2024 ...Petitioner .......Respondents RAJESH KUMAR 2024.08.01 09:22 I attest to the accuracy and authenticity of this order/judgment. Punjab & Haryana High Court, Chandigarh. CWP-21509-2023 BATRA RICE MILLS UNION OF INDIA AND OTHERS BATRA RICE MILLS UNION OF INDIA AND OTHERS M/S OHANA OVERSEAS UNION OF INDIA AND OTHERS M/S OHANA OVERSEAS UNION OF INDIA AND OTHERS M/S OHANA OVERSEAS UNION OF INDIA AND OTHERS Page 5 of 46 2023 (O&M) and connected cases. CWP Reserved on 24.07.2024 BATRA RICE MILLS V/S UNION OF INDIA AND OTHERS CWP Reserved on 24.07.2024 BATRA RICE MILLS V/S UNION OF INDIA AND OTHERS CWP Reserved on 24.07.2024 M/S OHANA OVERSEAS V/S UNION OF INDIA AND OTHERS CWP Reserved on 24.07.2024 M/S OHANA OVERSEAS V/S UNION OF INDIA AND OTHERS CWP Reserved on 24.07.2024 M/S OHANA OVERSEAS V/S UNION OF INDIA AND OTHERS and connected cases. CWP-13872-2023(O&M) Reserved on 24.07.2024 ...Petitioner ...Respondents CWP-13874-2023(O&M) Reserved on 24.07.2024 ...Petitioner ...Respondents CWP-13875-2023(O&M) Reserved on 24.07.2024 ...Petitioner ...Respondents CWP-13878-2023(O&M) Reserved on 24.07.2024 ...Petitioner ...Respondents CWP-13879-2023(O&M) Reserved on 24.07.2024 ...Petitioner ...Respondents RAJESH KUMAR 2024.08.01 09:22 I attest to the accuracy and authenticity of this order/judgment. Punjab & Haryana High Court, Chandigarh. CWP-21509-2023 RD RICE AND GENERAL MILLS UNION OF INDIA AND OTHERS M/S RANI RICE MILLS UNION OF INDIA AND OTHERS M/S MAHAVIR CEREALS UNION OF INDIA AND OTHERS SHANTI AGRO FOODS PVT LTD NATIONAL FACELESS ASSESSMENT CENTRE AND OTHERS SHANTI AGRO FOOD PVT. LTD. THROUGH ITS DIRECTOR SAHIL VERMA NATIONAL FACELESS ASSESSMENT CENTRE AND ORS. Page 6 of 46 2023 (O&M) and connected cases. CWP Reserved on 24.07.2024 RD RICE AND GENERAL MILLS V/S UNION OF INDIA AND OTHERS CWP Reserved M/S RANI RICE MILLS V/S UNION OF INDIA AND OTHERS CWP Reserved on 24.07.2024 M/S MAHAVIR CEREALS V/S UNION OF INDIA AND OTHERS CWP Reserved on 24.07.2024 SHANTI AGRO FOODS PVT LTD V/S NATIONAL FACELESS ASSESSMENT CENTRE AND OTHERS CWP Reserved on 24.07.2024 SHANTI AGRO FOOD PVT. LTD. THROUGH ITS DIRECTOR SAHIL V/S NATIONAL FACELESS ASSESSMENT CENTRE AND ORS. and connected cases. CWP-13881-2023(O&M) Reserved on 24.07.2024 ...Petitioner ...Respondents CWP-13886-2023(O&M) Reserved on 24.07.2024 ...Petitioner ...Respondents CWP-13919-2023(O&M) Reserved on 24.07.2024 ...Petitioner ...Respondents CWP-13935-2023 (O&M) Reserved on 24.07.2024 ...Petitioner NATIONAL FACELESS ASSESSMENT CENTRE AND OTHERS ...Respondents CWP-13987-2023(O&M) Reserved on 24.07.2024 SHANTI AGRO FOOD PVT. LTD. THROUGH ITS DIRECTOR SAHIL ...Petitioner NATIONAL FACELESS ASSESSMENT CENTRE AND ORS. ...Respondents SHANTI AGRO FOOD PVT. LTD. THROUGH ITS DIRECTOR SAHIL RAJESH KUMAR 2024.08.01 09:22 I attest to the accuracy and authenticity of this order/judgment. Punjab & Haryana High Court, Chandigarh. CWP-21509-2023 SHANTI AGRO FOODS PVT. LTD. THROUGH ITS DIRECTOR SAHIL VERMA NATIONAL FACELESS ASSESSMENT CENTRE AND ORS. BANSAL RICE AND GENERAL MILLS THROUGH PARTNER SH. PAWAN KUMAR NATIONAL FACELESS ASSESSMENT CENTRE DELHI THROUGH ADDITIONAL COMMISSIONER ATUL LAKHANPAL KUMAR UNION OF INDIA AND ORS BANSAL RICE AND GENERAL MILLS NATIONAL FACELESS ASSESSMENT CENTRE Page 7 of 46 2023 (O&M) and connected cases. CWP Reserved on 24.07.2024 SHANTI AGRO FOODS PVT. LTD. THROUGH ITS DIRECTOR SAHIL V/S NATIONAL FACELESS ASSESSMENT CENTRE AND ORS. CWP Reserved on 24.07.2024 BANSAL RICE AND GENERAL MILLS THROUGH PARTNER SH. PAWAN KUMAR V/S NATIONAL FACELESS ASSESSMENT CENTRE DELHI THROUGH ADDITIONAL COMMISSIONER CWP Reserved on 24.07.2024 ATUL LAKHANPAL KUMAR V/S UNION OF INDIA AND ORS CWP Reserved on 24.07.2024 BANSAL RICE AND GENERAL MILLS V/S NATIONAL FACELESS ASSESSMENT CENTRE and connected cases. CWP-13991-2023(O&M) Reserved on 24.07.2024 SHANTI AGRO FOODS PVT. LTD. THROUGH ITS DIRECTOR SAHIL ...Petitioner NATIONAL FACELESS ASSESSMENT CENTRE AND ORS. ...Respondents CWP-14045-2023(O&M) Reserved on 24.07.2024 BANSAL RICE AND GENERAL MILLS THROUGH PARTNER SH. ...Petitioner NATIONAL FACELESS ASSESSMENT CENTRE DELHI THROUGH ...Respondent CWP-14062-2023(O&M) Reserved on 24.07.2024 ...Petitioner ...Respondents CWP-14074-2023 (O&M) Reserved on 24.07.2024 ...Petitioner NATIONAL FACELESS ASSESSMENT CENTRE ...Respondent SHANTI AGRO FOODS PVT. LTD. THROUGH ITS DIRECTOR SAHIL BANSAL RICE AND GENERAL MILLS THROUGH PARTNER SH. NATIONAL FACELESS ASSESSMENT CENTRE DELHI THROUGH RAJESH KUMAR 2024.08.01 09:22 I attest to the accuracy and authenticity of this order/judgment. Punjab & Haryana High Court, Chandigarh. CWP-21509-2023 NEERAJ BATRA NATIONAL FACELESS ASSESSM RATTAN LAL CENTRAL BOARD OF DIRECT TAXES AND ORS. BANSAL RICE AND GENERAL MILLS NATIONAL FACELESS ASSESSMENT CENTRE, AND ORS. SANDEEP AGRO FOODS CBDT AND ORS. R.K. OVERSEAS NATIONAL FACELESS ASSESSMENT CENTRE AND ORS. Page 8 of 46 2023 (O&M) and connected cases. CWP Reserved on 24.07.2024 NEERAJ BATRA V/S NATIONAL FACELESS ASSESSMENT CENTRE CWP Reserved on 24.07.2024 RATTAN LAL V/S CENTRAL BOARD OF DIRECT TAXES AND ORS. CWP Reserved on 24.07.2024 BANSAL RICE AND GENERAL MILLS V/S NATIONAL FACELESS ASSESSMENT CENTRE, AND ORS. CWP Reserved on 24.07.2024 SANDEEP AGRO FOODS V/S CBDT AND ORS. CWP Reserved on R.K. OVERSEAS V/S NATIONAL FACELESS ASSESSMENT CENTRE AND ORS. and connected cases. CWP-14108-2023(O&M) Reserved on 24.07.2024 ...Petitioner ENT CENTRE ...Respondent CWP-14124-2023(O&M) Reserved on 24.07.2024 ...Petitioner CENTRAL BOARD OF DIRECT TAXES AND ORS. ...Respondents CWP-14179-2023(O&M) Reserved on 24.07.2024 ...Petitioner NATIONAL FACELESS ASSESSMENT CENTRE, AND ORS. ...Respondents CWP-14184-2023(O&M) Reserved on 24.07.2024 ...Petitioner ...Respondents CWP-14202-2023(O&M) Reserved on 24.07.2024 ...Petitioner NATIONAL FACELESS ASSESSMENT CENTRE AND ORS. ...Respondents ...Respondents ...Respondents RAJESH KUMAR 2024.08.01 09:22 I attest to the accuracy and authenticity of this order/judgment. Punjab & Haryana High Court, Chandigarh. CWP-21509-2023 R.K. OVERSEAS NATIONAL FACELESS ASSESSMENT CENTRE AND OTHERS S K FOODS NISSING THROUGH ITS PARTNER CENTRAL BOARD OF DIRECT TAXES AND ORS. AVTAR SINGH UNION OF INDIA AND ORS ALFANAR ENERGY PVT. LTD. UNION OF INIDA AND ORS. GURU NANAK KHALSA SR. SEC. SCHOOL INCOME TAX OFFICER AND ORS. Page 9 of 46 2023 (O&M) and connected cases. CWP Reserved on 24.07.2024 R.K. OVERSEAS V/S NATIONAL FACELESS ASSESSMENT CENTRE AND OTHERS CWP Reserved on 24.07.2024 S K FOODS NISSING THROUGH ITS PARTNER V/S CENTRAL BOARD OF DIRECT TAXES AND ORS. CWP Reserved on 24.07.2024 AVTAR SINGH V/S UNION OF INDIA AND ORS CWP Reserved on 24.07.2024 ALFANAR ENERGY PVT. LTD. V/S UNION OF INIDA AND ORS. CWP Reserved on 24.07.2024 GURU NANAK KHALSA SR. SEC. SCHOOL V/S INCOME TAX OFFICER AND ORS. and connected cases. CWP-14206-2023(O&M) Reserved on 24.07.2024 ...Petitioner NATIONAL FACELESS ASSESSMENT CENTRE AND OTHERS ...Respondents CWP-14695-2023(O&M) Reserved on 24.07.2024 S K FOODS NISSING THROUGH ITS PARTNER ...Petitioner CENTRAL BOARD OF DIRECT TAXES AND ORS. ...Respondents CWP-15963-2023(O&M) Reserved on 24.07.2024 ...Petitioner ...Respondents CWP-16351-2023(O&M) Reserved on 24.07.2024 ...Petitioner ...Respondents CWP-17414-2023(O&M) Reserved on 24.07.2024 GURU NANAK KHALSA SR. SEC. SCHOOL ...Petitioner ...Respondents ...Respondents s RAJESH KUMAR 2024.08.01 09:22 I attest to the accuracy and authenticity of this order/judgment. Punjab & Haryana High Court, Chandigarh. CWP-21509-2023 PARDIP SINGH SANDHU PR. COMMISSIONER OF INCOME TAX AND ORS. M/S JLD ESTATES PVT LTD INCOME TAX OFFICER WARD 6(1) MUKESH KUMAR GARG CENTRAL BOARD OF DIRECT TAXES AND ORS MUKESH KUMAR GARG CENTRAL BOARD OF DIRECT TAXES AND OTHERS D.M. COLLEGE OF EDUCATION INCOME TAX OFFICER AND ORS. Page 10 of 46 2023 (O&M) and connected cases. CWP Reserved on 24.07.2024 PARDIP SINGH SANDHU V/S PR. COMMISSIONER OF INCOME TAX AND ORS. CWP Reserved on 24.07.2024 M/S JLD ESTATES PVT LTD V/S INCOME TAX OFFICER WARD 6(1) CWP Reserved on 24.07.2024 MUKESH KUMAR GARG V/S CENTRAL BOARD OF DIRECT TAXES AND ORS CWP Reserved on 24.07.2024 MUKESH KUMAR GARG V/S CENTRAL BOARD OF DIRECT TAXES AND OTHERS CWP Reserved on 24.07.2024 D.M. COLLEGE OF EDUCATION V/S INCOME TAX OFFICER AND ORS. 46 and connected cases. CWP-17513-2023 (O&M) Reserved on 24.07.2024 ...Petitioner PR. COMMISSIONER OF INCOME TAX AND ORS. ...Respondents CWP-12714-2023(O&M) Reserved on 24.07.2024 ...Petitioner ...Respondent CWP-13133-2023(O&M) Reserved on 24.07.2024 ...Petitioner CENTRAL BOARD OF DIRECT TAXES AND ORS ...Respondents CWP-13147-2023(O&M) Reserved on 24.07.2024 ...Petitioner CENTRAL BOARD OF DIRECT TAXES AND OTHERS...Respondents CWP-20203-2023(O&M) Reserved on 24.07.2024 ...Petitioner ...Respondents RAJESH KUMAR 2024.08.01 09:22 I attest to the accuracy and authenticity of this order/judgment. Punjab & Haryana High Court, Chandigarh. CWP-21509-2023 ASHWANI KUMAR AGGARWAL UNION OF INDIA AND OTHERS GURU NANAK KHALSA SR. SEC. SCHOOL INCOME TAX OFFICER AND OTHERS GURU NANAK KHALSA SR. SEC. SCHOOL INCOME TAX OFFICER AND SAHI SIALKOT RETAIL OUTLET AND FILLING STATION INCOME TAX OFFICER AND OTHERS BALINDER KAUR NATIONAL FACELESS ASSESSMENT CENRTRE AND ORS. Page 11 of 46 2023 (O&M) and connected cases. CWP Reserved on 24.07.2024 ASHWANI KUMAR AGGARWAL V/S UNION OF INDIA AND OTHERS CWP Reserved on 24.07.2024 GURU NANAK KHALSA SR. SEC. SCHOOL V/S INCOME TAX OFFICER AND OTHERS CWP Reserved on 24.07.2024 GURU NANAK KHALSA SR. SEC. SCHOOL V/S INCOME TAX OFFICER AND OTHERS CWP Reserved on 24.07.2024 SAHI SIALKOT RETAIL OUTLET AND FILLING STATION V/S INCOME TAX OFFICER AND OTHERS CWP Reserved on 24.07.2024 BALINDER KAUR V/S NATIONAL FACELESS ASSESSMENT CENRTRE AND ORS. 46 and connected cases. CWP-22645-2023 (O&M) Reserved on 24.07.2024 ...Petitioner ...Respondents CWP-22972-2023(O&M) Reserved on 24.07.2024 GURU NANAK KHALSA SR. SEC. SCHOOL ...Petitioner ...Respondents CWP-23128-2023 (O&M) Reserved on 24.07.2024 GURU NANAK KHALSA SR. SEC. SCHOOL ...Petitioner ...Respondents CWP-23187-2023(O&M) Reserved on 24.07.2024 SAHI SIALKOT RETAIL OUTLET AND FILLING STATION .....Petitioner ...Respondents CWP-23292-2023(O&M) Reserved on 24.07.2024 ...Petitioner NATIONAL FACELESS ASSESSMENT CENRTRE AND ORS. ...Respondents RAJESH KUMAR 2024.08.01 09:22 I attest to the accuracy and authenticity of this order/judgment. Punjab & Haryana High Court, Chandigarh. CWP-21509-2023 DIDAR SINGH SEKHON NATIONAL FACELESS ASSESSMENT CENRTRE AND ORS. NAVEEN TIMBER PRIVATE LTD UNION OF INDIA AND OTHERS BALDEV SINGH. NATIONAL FACELESS ASSESSMENT CENTRE AND ORS. SUSHMA RANI NATIONAL FACELESS ASSESSMENT CENRTRE AND ORS. SIMERJIT KAUR SANDHU UNION OF INDIA AND OTHERS Page 12 of 46 2023 (O&M) and connected cases. CWP Reserved on 24.07.2024 DIDAR SINGH SEKHON V/S NATIONAL FACELESS ASSESSMENT CENRTRE AND ORS. CWP Reserved on 24.07.2024 NAVEEN TIMBER PRIVATE LTD V/S UNION OF INDIA AND OTHERS CWP Reserved on 24.07.2024 BALDEV SINGH. V/S NATIONAL FACELESS ASSESSMENT CENTRE AND ORS. CWP Reserved on 24.07.2024 SUSHMA RANI V/S NATIONAL FACELESS ASSESSMENT CENRTRE AND ORS. CWP Reserved on 24.07.2024 SIMERJIT KAUR SANDHU V/S UNION OF INDIA AND OTHERS 46 and connected cases. CWP-23293-2023(O&M) Reserved on 24.07.2024 ...Petitioner NATIONAL FACELESS ASSESSMENT CENRTRE AND ORS. ...Respondents CWP-23318-2023(O&M) Reserved on 24.07.2024 ...Petitioner ...Respondents CWP-23324-2023(O&M) Reserved on 24.07.2024 .…...Petitioner NATIONAL FACELESS ASSESSMENT CENTRE AND ORS. ...Respondents CWP-23342-2023(O&M) Reserved on 24.07.2024 ...Petitioner NATIONAL FACELESS ASSESSMENT CENRTRE AND ORS. ...Respondents CWP-15145-2023(O&M) Reserved on 24.07.2024 ...Petitioner ...Respondents RAJESH KUMAR 2024.08.01 09:22 I attest to the accuracy and authenticity of this order/judgment. Punjab & Haryana High Court, Chandigarh. CWP-21509-2023 HARMEET SINGH INCOME TAX OFFICER SUSHMA RANI @ SUSHMA SINGLA, W/O SH. MURARI LAL AGED ABOUT 46 YEARS RESIDENT OF HOUSE NO. 658, SECT NATIONAL FACELESS ASSESSMENT CENTRE, DELHI AND OTHERS RUBY NATIONAL FACELESS ASSESSMENT CENTRE DELHI ROMA GUPTA NATIONAL FACELESS ASSESSMENT CENTRE DELHI AND OTHERS SUCHETAN BHALLA NATIONAL FACELESS ASSESSMENT CENTRE, DELHI AND OTHERS Page 13 of 46 2023 (O&M) and connected cases. CWP Reserved on 24.07.2024 HARMEET SINGH V/S INCOME TAX OFFICER CWP Reserved on 24.07.2024 SUSHMA RANI @ SUSHMA SINGLA, W/O SH. MURARI LAL AGED ABOUT 46 YEARS RESIDENT OF HOUSE NO. 658, SECT V/S NATIONAL FACELESS ASSESSMENT CENTRE, DELHI AND OTHERS CWP Reserved on 24.07.2024 V/S NATIONAL FACELESS ASSESSMENT CENTRE DELHI CWP Reserved on 24.07.2024 ROMA GUPTA V/S NATIONAL FACELESS ASSESSMENT CENTRE DELHI AND OTHERS CWP Reserved on 24.07.2024 SUCHETAN BHALLA V/S NATIONAL FACELESS ASSESSMENT CENTRE, DELHI AND OTHERS 46 and connected cases. CWP-6617-2024 (O&M) Reserved on 24.07.2024 ...Petitioner ...Respondent CWP-2348-2024 (O&M) Reserved on 24.07.2024 SUSHMA RANI @ SUSHMA SINGLA, W/O SH. MURARI LAL AGED ABOUT 46 YEARS RESIDENT OF HOUSE NO. 658, SECT ...Petitioner NATIONAL FACELESS ASSESSMENT CENTRE, DELHI AND OTHERS ...Respondents CWP-3096-2024 (O&M) Reserved on 24.07.2024 ...Petitioner NATIONAL FACELESS ASSESSMENT CENTRE DELHI ...Respondent CWP-3227-2024 (O&M) Reserved on 24.07.2024 ...Petitioner NATIONAL FACELESS ASSESSMENT CENTRE DELHI AND OTHERS ...Respondents CWP-5011-2024(O&M) Reserved on 24.07.2024 ...Petitioner NATIONAL FACELESS ASSESSMENT CENTRE, DELHI AND OTHERS ...Respondents SUSHMA RANI @ SUSHMA SINGLA, W/O SH. MURARI LAL AGED NATIONAL FACELESS ASSESSMENT CENTRE, DELHI AND OTHERS s NATIONAL FACELESS ASSESSMENT CENTRE, DELHI AND OTHERS s RAJESH KUMAR 2024.08.01 09:22 I attest to the accuracy and authenticity of this order/judgment. Punjab & Haryana High Court, Chandigarh. CWP-21509-2023 NARESH KUMAR CHAWLA UNION OF INDIA AND ORS SRI HARI HAR OVERSEAS PRIVATE LIMITED NATIONAL FACELESS ASSESSMENT CENTRE DELHI AND OTHERS RAJESH KUMAR NATIONAL FACELESS ASSESSMENT CENTRE DELHI AND ORS. R.G. INTERNATIONAL PRIVATE LIMITED NATIONAL FACELESS ASSESSMENT CENTRE DELHI SARABJIT SINGH UNION OF INDIA AND ORS Page 14 of 46 2023 (O&M) and connected cases. CWP Reserved on 24.07.2024 NARESH KUMAR CHAWLA V/S UNION OF INDIA AND ORS CWP Reserved on 24.07.2024 SRI HARI HAR OVERSEAS PRIVATE LIMITED V/S NATIONAL FACELESS ASSESSMENT CENTRE DELHI AND OTHERS CWP Reserved on 24.07.2024 RAJESH KUMAR V/S NATIONAL FACELESS ASSESSMENT CENTRE DELHI AND ORS. CWP Reserved on 24.07.2024 R.G. INTERNATIONAL PRIVATE LIMITED V/S NATIONAL FACELESS ASSESSMENT CENTRE DELHI CWP Reserved on 24.07.2024 SARABJIT SINGH V/S UNION OF INDIA AND ORS 46 and connected cases. CWP-4211-2024 (O&M) Reserved on 24.07.2024 ...Petitioner ......Respondents CWP-4158-2024 (O&M) Reserved on 24.07.2024 SRI HARI HAR OVERSEAS PRIVATE LIMITED ...Petitioner NATIONAL FACELESS ASSESSMENT CENTRE DELHI AND OTHERS ......Respondents CWP-3568-2024(O&M) Reserved on 24.07.2024 ...Petitioner NATIONAL FACELESS ASSESSMENT CENTRE DELHI AND ORS. ......Respondent s CWP-4138-2024(O&M) Reserved on 24.07.2024 R.G. INTERNATIONAL PRIVATE LIMITED ...Petitioner NATIONAL FACELESS ASSESSMENT CENTRE DELHI AND OTHERS ......Respondents CWP-7801-2024(O&M) Reserved on 24.07.2024 ...Petitioner ......Respondents AND OTHERS RAJESH KUMAR 2024.08.01 09:22 I attest to the accuracy and authenticity of this order/judgment. Punjab & Haryana High Court, Chandigarh. CWP-21509-2023 MANISH KUMAR JAIN INCOME TAX OFFICER AND ORS SOCOMO TECHNOLOGIES PRIVATE LIMITED UNION OF INDIA AND OTHERS VINAY KAUSHAL DEPUTY COMMISSIONER INCOME TAX CIRCLE AAYAKAR BHAWAN HERO CYCLES LTD NATIONAL FACELESS ASSESSMENT CENTRE HERO CYCLES LTD NATIONAL FACELESS ASSESSMENT CENTRE, DELHI AND OTHERS Page 15 of 46 2023 (O&M) and connected cases. CWP Reserved on 24.07.2024 MANISH KUMAR JAIN V/S INCOME TAX OFFICER AND ORS CWP Reserved on 24.07.2024 SOCOMO TECHNOLOGIES PRIVATE LIMITED V/S UNION OF INDIA AND OTHERS CWP Reserved on 24.07.2024 VINAY KAUSHAL V/S DEPUTY COMMISSIONER INCOME TAX CIRCLE AAYAKAR CWP Reserved on 24.07.2024 HERO CYCLES LTD V/S NATIONAL FACELESS ASSESSMENT CENTRE CWP Reserved on 24.07.2024 HERO CYCLES LTD V/S NATIONAL FACELESS ASSESSMENT CENTRE, DELHI AND OTHERS 46 and connected cases. CWP-14345-2024(O&M) Reserved on 24.07.2024 ...Petitioner ......Respondents CWP-8513-2024 (O&M) Reserved on 24.07.2024 SOCOMO TECHNOLOGIES PRIVATE LIMITED ...Petitioner ......Respondents CWP-9662-2024 (O&M) Reserved on 24.07.2024 ...Petitioner DEPUTY COMMISSIONER INCOME TAX CIRCLE AAYAKAR ......Respondent CWP-8667-2024(O&M) Reserved on 24.07.2024 ...Petitioner NATIONAL FACELESS ASSESSMENT CENTRE ......Respondent CWP-8668-2024(O&M) Reserved on 24.07.2024 ...Petitioner NATIONAL FACELESS ASSESSMENT CENTRE, DELHI AND OTHERS ......Respondents DEPUTY COMMISSIONER INCOME TAX CIRCLE AAYAKAR NATIONAL FACELESS ASSESSMENT CENTRE, DELHI AND OTHERS RAJESH KUMAR 2024.08.01 09:22 I attest to the accuracy and authenticity of this order/judgment. Punjab & Haryana High Court, Chandigarh. CWP-21509-2023 MUNISH GOYAL UNION OF INDIA AND OTHERS CHANCHAL GOYAL UNION OF INDIA AND OTHERS ROCKMAN INDUSTRIES NATIONAL FACELESS ASSESSMENT CENTRE ROCKMAN INDUSTRIES LIMITED NATIONAL FACELESS ASSESSMENT CENTRE, DELHI AND OTHERS ROCKMAN INDUSTRIES LIMITED NATIONAL FACELESS ASSESSMENT CENTRE, DELHI ...... Page 16 of 46 2023 (O&M) and connected cases. CWP Reserved on 24.07.2024 MUNISH GOYAL V/S UNION OF INDIA AND OTHERS CWP Reserved on 24.07.2024 CHANCHAL GOYAL V/S UNION OF INDIA AND OTHERS CWP Reserved on 24.07.2024 ROCKMAN INDUSTRIES LIMITED V/S NAL FACELESS ASSESSMENT CENTRE CWP Reserved on 24.07.2024 ROCKMAN INDUSTRIES LIMITED V/S NATIONAL FACELESS ASSESSMENT CENTRE, DELHI AND OTHERS CWP Reserved on 24.07.2024 ROCKMAN INDUSTRIES LIMITED V/S NATIONAL FACELESS ASSESSMENT CENTRE, DELHI ...... 46 and connected cases. CWP-9078-2024 (O&M) Reserved on 24.07.2024 ...Petitioner ......Respondents CWP-9081-2024 (O&M) Reserved on 24.07.2024 ...Petitioner ......Respondents CWP-9252-2024(O&M) Reserved on 24.07.2024 ...Petitioner NAL FACELESS ASSESSMENT CENTRE ......Respondent CWP-9264-2024(O&M) Reserved on 24.07.2024 ...Petitioner NATIONAL FACELESS ASSESSMENT CENTRE, DELHI AND OTHERS ......Respondents CWP-9422-2024(O&M) Reserved on 24.07.2024 ...Petitioner NATIONAL FACELESS ASSESSMENT CENTRE, DELHI ......Respondent NATIONAL FACELESS ASSESSMENT CENTRE, DELHI AND OTHERS RAJESH KUMAR 2024.08.01 09:22 I attest to the accuracy and authenticity of this order/judgment. Punjab & Haryana High Court, Chandigarh. CWP-21509-2023 VARINDER KAUSHAL UNION OF INDIA AND OTHERS ANURAG WADHWA NATIONAL FACELESS ASSESSMENT CENTRE DELHI AND OTHERS SOCOMO TECHNOLOGIES PRIVATE LIMITED UNION OF INDIA AND OTHERS ANURAG WADHWA NATIONAL FACELESS ASSESSMENT CENTRE, DELHI AND OTHERS ANURAG WADHWA NATIONAL FACELESS ASSESSMENT CENTRE, DELHI AND OTHERS Page 17 of 46 2023 (O&M) and connected cases. CWP Reserved on 24.07.2024 VARINDER KAUSHAL V/S UNION OF INDIA AND OTHERS CWP Reserved on 24.07.2024 ANURAG WADHWA V/S NATIONAL FACELESS ASSESSMENT CENTRE DELHI AND OTHERS CWP Reserved SOCOMO TECHNOLOGIES PRIVATE LIMITED V/S UNION OF INDIA AND OTHERS CWP Reserved on 24.07.2024 ANURAG WADHWA V/S NATIONAL FACELESS ASSESSMENT CENTRE, DELHI AND OTHERS CWP Reserved on 24.07.2024 ANURAG WADHWA V/S NATIONAL FACELESS ASSESSMENT CENTRE, DELHI AND OTHERS 46 and connected cases. CWP-9570-2024 (O&M) Reserved on 24.07.2024 ...Petitioner ......Respondents CWP-9572-2024(O&M) Reserved on 24.07.2024 ...Petitioner NATIONAL FACELESS ASSESSMENT CENTRE DELHI AND OTHERS ......Respondents CWP-8519-2024(O&M) Reserved on 24.07.2024 SOCOMO TECHNOLOGIES PRIVATE LIMITED ...Petitioner ......Respondents CWP-9821-2024(O&M) Reserved on 24.07.2024 ...Petitioner NATIONAL FACELESS ASSESSMENT CENTRE, DELHI AND OTHERS ......Respondents CWP-9823-2024(O&M) Reserved on 24.07.2024 ...Petitioner NATIONAL FACELESS ASSESSMENT CENTRE, DELHI AND OTHERS ......Respondents NATIONAL FACELESS ASSESSMENT CENTRE DELHI AND OTHERS NATIONAL FACELESS ASSESSMENT CENTRE, DELHI AND OTHERS NATIONAL FACELESS ASSESSMENT CENTRE, DELHI AND OTHERS RAJESH KUMAR 2024.08.01 09:22 I attest to the accuracy and authenticity of this order/judgment. Punjab & Haryana High Court, Chandigarh. CWP-21509-2023 SHINGARA SINGH SIDHU UNION OF INDIA AND OTHERS SHINGARA SINGH SIDHU UNION OF INDIA AND OTHERS AAR DEE ENTERPRISES UNION OF INDIA AND OTHERS PUNEET ARORA UNION OF INDIA AND OTHERS ANURAG AGGARWAL PROP M/S A STAR EXPORT INCOME TAX OFFICER WARD Page 18 of 46 2023 (O&M) and connected cases. CWP Re SHINGARA SINGH SIDHU V/S UNION OF INDIA AND OTHERS CWP Reserved on 24.07.2024 SHINGARA SINGH SIDHU V/S UNION OF INDIA AND OTHERS CWP Reserved on 24.07.2024 AAR DEE ENTERPRISES V/S UNION OF INDIA AND OTHERS CWP Reserved on 24.07.2024 PUNEET ARORA V/S UNION OF INDIA AND OTHERS CWP Reserved on 24.07.2024 ANURAG AGGARWAL PROP M/S A STAR EXPORT V/S INCOME TAX OFFICER WARD-1(5) LUDHIANA AND OTHERS 46 and connected cases. CWP-10109-2024(O&M) Reserved on 24.07.2024 ...Petitioner ......Respondent CWP-10280-2024(O&M) Reserved on 24.07.2024 ...Petitioner ......Respondents CWP-10348-2024 (O&M) Reserved on 24.07.2024 ...Petitioner ......Respondents CWP-10404-2024(O&M) Reserved on 24.07.2024 ...Petitioner ......Respondents CWP-10568-2024 (O&M) Reserved on 24.07.2024 ANURAG AGGARWAL PROP M/S A STAR EXPORT ...Petitioner 1(5) LUDHIANA AND OTHERS ......Respondents RAJESH KUMAR 2024.08.01 09:22 I attest to the accuracy and authenticity of this order/judgment. Punjab & Haryana High Court, Chandigarh. CWP-21509-2023 BMR ADVISORS LLP THE INCOME TAX OFFICER RITU VERMA UNION OF INDIA AND OTHERS SUHAIL SETH UNION OF INDIA AND OTHERS HARISH NANDA INCOME TAX OFFICER WARD 1 M/S JASDEEP KAUR CHADHA DCIT CIRCLE 4, JALANDHAR Page 19 of 46 2023 (O&M) and connected cases. CWP Reserved on 24.07.2024 BMR ADVISORS LLP V/S THE INCOME TAX OFFICER CWP Reserved on 24.07.2024 RITU VERMA V/S UNION OF INDIA AND OTHERS CWP Reserved on SUHAIL SETH V/S UNION OF INDIA AND OTHERS CWP Reserved on 24.07.2024 HARISH NANDA V/S INCOME TAX OFFICER WARD 1 CWP Reserved on 24.07.2024 M/S JASDEEP KAUR CHADHA V/S DCIT CIRCLE 4, JALANDHAR 46 and connected cases. CWP-10571-2024 (O&M) Reserved on 24.07.2024 ...Petitioner ......Respondent CWP-10964-2024 (O&M) Reserved on 24.07.2024 ...Petitioner ......Respondents CWP-10977-2024 (O&M) Reserved on 24.07.2024 ...Petitioner ......Respondents CWP-10978-2024 (O&M) Reserved on 24.07.2024 ...Petitioner ......Respondent CWP-11115-2024(O&M) Reserved on 24.07.2024 ...Petitioner ......Respondents RAJESH KUMAR 2024.08.01 09:22 I attest to the accuracy and authenticity of this order/judgment. Punjab & Haryana High Court, Chandigarh. CWP-21509-2023 AMRIT OILS CHEMICALS ASSISSTANT COMMISSIONER OF INCOME TAX SUKHDIP SINGH INCOME TAX OFFICER AND OTHERS VISHAL SPINNING MILLS UNION OF INDIA AND OTHERS YUVRAJ SINGH JOHAR UNION OF INDIA AND OTHERS YUVRAJ SINGH JOHAR UNION OF INDIA AND OTHERS Page 20 of 46 2023 (O&M) and connected cases. CWP Reserved on 24.07.2024 AMRIT OILS CHEMICALS V/S ASSISSTANT COMMISSIONER OF INCOME TAX CWP Reserved on 24.07.2024 SUKHDIP SINGH V/S INCOME TAX OFFICER AND OTHERS CWP Reserved on 24.07.2024 VISHAL SPINNING MILLS V/S UNION OF INDIA AND OTHERS CWP Reserved on 24.07.2024 YUVRAJ SINGH JOHAR V/S UNION OF INDIA AND OTHERS CWP Reserved on 24.07.2024 YUVRAJ SINGH JOHAR V/S UNION OF INDIA AND OTHERS 46 and connected cases. CWP-11232-2024(O&M) Reserved on 24.07.2024 ...Petitioner ASSISSTANT COMMISSIONER OF INCOME TAX ......Respondent CWP-11354-2024(O&M) Reserved on 24.07.2024 ...Petitioner ......Respondents CWP-11495-2024 (O&M) Reserved on 24.07.2024 ...Petitioner ......Respondents CWP-11517-2024(O&M) Reserved on 24.07.2024 ...Petitioner ......Respondents CWP-11519-2024 (O&M) Reserved on 24.07.2024 ...Petitioner ......Respondents RAJESH KUMAR 2024.08.01 09:22 I attest to the accuracy and authenticity of this order/judgment. Punjab & Haryana High Court, Chandigarh. CWP-21509-2023 D.M. COLLEGE MOGA INCOME TAX OFFICER AND OTHERS DM COLLEGE INCOME TAX OFFICER AND OTHERS BHARAT BHUSHAN KHURANA INCOME TAX OFFICER MIDLAND MICROFIN LIMITED ASSISTANT COMMISSIONER OF INCOME TAX AND OTHERS DEEPAK GUPTA INCOME TAX OFFICER Page 21 of 46 2023 (O&M) and connected cases. CWP Reserved on 24.07.2024 D.M. COLLEGE MOGA V/S INCOME TAX OFFICER AND OTHERS CWP Reserved on DM COLLEGE V/S INCOME TAX OFFICER AND OTHERS CWP Reserved on 24.07.2024 BHARAT BHUSHAN KHURANA V/S INCOME TAX OFFICER CWP Reserved on 24.07.2024 MIDLAND MICROFIN LIMITED V/S ASSISTANT COMMISSIONER OF INCOME TAX AND OTHERS CWP Reserved on 24.07.2024 DEEPAK GUPTA V/S INCOME TAX OFFICER AND ORS 46 and connected cases. CWP-11659-2024 (O&M) Reserved on 24.07.2024 ...Petitioner ......Respondents CWP-11661-2024(O&M) Reserved on 24.07.2024 ...Petitioner ......Respondents CWP-11783-2024(O&M) Reserved on 24.07.2024 ...Petitioner ......Respondent CWP-11949-2024(O&M) Reserved on 24.07.2024 ...Petitioner ASSISTANT COMMISSIONER OF INCOME TAX AND OTHERS ......Respondents CWP-12048-2024(O&M) Reserved on 24.07.2024 ...Petitioner ......Respondents RAJESH KUMAR 2024.08.01 09:22 I attest to the accuracy and authenticity of this order/judgment. Punjab & Haryana High Court, Chandigarh. CWP-21509-2023 M/S EXETER METBIZ INDIA PVT LTD UNION OF INDIA AND OTHERS EXETER METBIZ INDIA PVT LTD UNION OF INDIA AND OTHERS SR IMPEX PRIVATE LIMITED UNION OF INDIA AND OTHERS ASHA KAHLON V/S PRINCIPAL CHIEF COMMISSIONER DM COLLEGE OF EDUCATION INCOME TAX OFFICER & ORS Page 22 of 46 2023 (O&M) and connected cases. CWP Reserved on 24.07.2024 M/S EXETER METBIZ INDIA PVT LTD V/S UNION OF INDIA AND OTHERS CWP Reserved on 24.07.2024 EXETER METBIZ INDIA PVT LTD V/S UNION OF INDIA AND OTHERS CWP Reserved on 24.07.2024 SR IMPEX PRIVATE LIMITED V/S UNION OF INDIA AND OTHERS CWP Reserved on 24.07.2024 ASHA KAHLON PRINCIPAL CHIEF COMMISSIONER OF INCOME TAX AND OTHER CWP Reserved on 24.07.2024 DM COLLEGE OF EDUCATION V/S INCOME TAX OFFICER & ORS 46 and connected cases. CWP-12159-2024(O&M) Reserved on 24.07.2024 ...Petitioner ......Respondents CWP-12190-2024(O&M) Reserved on 24.07.2024 ...Petitioner ......Respondents CWP-12360-2024(O&M) Reserved on 24.07.2024 ...Petitioner ......Respondents CWP-12366-2024 (O&M) Reserved on 24.07.2024 …Petitioner OF INCOME TAX AND OTHERS …Respondents CWP-12370-2024 (O&M) Reserved on 24.07.2024 ...Petitioner ......Respondents RAJESH KUMAR 2024.08.01 09:22 I attest to the accuracy and authenticity of this order/judgment. Punjab & Haryana High Court, Chandigarh. CWP-21509-2023 DM COLLEGE OF EDUCATION INCOME TAX OFFICER AND OTHERS SUNAINA AUJLA UNION OF INDIA AND OTHERS SIYA RAM GARG UNION OF INDIA AND OTHERS RATISH VERMA DEPUTY COMMISSIONER OF INCOME TAX AND ORS M K PROTEINS LIMITED INCOME TAX OFFICER AND OTHERS Page 23 of 46 2023 (O&M) and connected cases. CWP Reserved on 24.07.2024 DM COLLEGE OF EDUCATION V/S INCOME TAX OFFICER AND OTHERS CWP Reserved on 24.07.2024 SUNAINA AUJLA V/S UNION OF INDIA AND OTHERS CWP Reserved on 24.07.2024 SIYA RAM GARG V/S UNION OF INDIA AND OTHERS CWP Reserved on 24.07.2024 RATISH VERMA V/S DEPUTY COMMISSIONER OF INCOME TAX AND ORS CWP Reserved on 24.07.2024 M K PROTEINS LIMITED V/S INCOME TAX OFFICER AND OTHERS 46 and connected cases. CWP-12371-2024 (O&M) Reserved on 24.07.2024 ...Petitioner ......Respondents CWP-12579-2024 (O&M) Reserved on 24.07.2024 ...Petitioner ......Respondents CWP-12736-2024 (O&M) Reserved on 24.07.2024 ...Petitioner ......Respondents CWP-12740-2024 (O&M) Reserved on 24.07.2024 ...Petitioner DEPUTY COMMISSIONER OF INCOME TAX AND ORS ......Respondents CWP-12743-2024 (O&M) Reserved on 24.07.2024 ...Petitioner ......Respondents RAJESH KUMAR 2024.08.01 09:22 I attest to the accuracy and authenticity of this order/judgment. Punjab & Haryana High Court, Chandigarh. CWP-21509-2023 M K PROTEINS LIMITED INCOME TAX OFFICER AND OTHERS TANMEET KAUR SOKHI UNION OF INDIA AND ORS TANMEET KAUR SOKHI UNION OF INDIA AND ORS SUKHJINDER KAUR UNION OF INDIA AND OTHERS ADESH KUMAR GUPTA DEPUTY COMMISSIONER OF INCOME TAX CIR, Page 24 of 46 2023 (O&M) and connected cases. CWP Reserved on 24.07.2024 M K PROTEINS LIMITED V/S INCOME TAX OFFICER AND OTHERS CWP Reserved on 24.07.2024 TANMEET KAUR SOKHI V/S UNION OF INDIA AND ORS CWP Reserved on 24.07.2024 TANMEET KAUR SOKHI V/S UNION OF INDIA AND ORS CWP Reserved on 24.07.2024 SUKHJINDER KAUR V/S UNION OF INDIA AND OTHERS CWP Reserved on 24.07.2024 ADESH KUMAR GUPTA V/S DEPUTY COMMISSIONER OF INCOME TAX CIR, 46 and connected cases. CWP-12750-2024 (O&M) Reserved on 24.07.2024 ...Petitioner ......Respondents CWP-12796-2024 (O&M) Reserved on 24.07.2024 ...Petitioner ......Respondents CWP-12867-2024 (O&M) Reserved on 24.07.2024 ...Petitioner ......Respondents CWP-13348-2024 (O&M) Reserved on 24.07.2024 ...Petitioner ......Respondents CWP-13354-2024(O&M) Reserved on 24.07.2024 ...Petitioner DEPUTY COMMISSIONER OF INCOME TAX CIR, KARNAL ......Respondent RAJESH KUMAR 2024.08.01 09:22 I attest to the accuracy and authenticity of this order/judgment. Punjab & Haryana High Court, Chandigarh. CWP-21509-2023 M/S STALWART ALLOYS INDIA LTD UNION OF INDIA AND ORS TANIA VERMA DEPUTY COMMISSIONER OF INCOME TAX AND ORS...... M K PROTEINS LIMITED INCOME TAX OFFICER AND OTHERS SAHIB SINGH UNION OF INDIA AND OTHERS ASHISH MAURYA UNION OF INDIA AND OTHERS Page 25 of 46 2023 (O&M) and connected cases. CWP Reserved on 24.07.2024 M/S STALWART ALLOYS INDIA LTD V/S UNION OF INDIA AND ORS CWP Reserved on 24.07.2024 TANIA VERMA V/S DEPUTY COMMISSIONER OF INCOME TAX AND ORS...... CWP Reserved on 24.07.2024 M K PROTEINS LIMITED V/S INCOME TAX OFFICER AND OTHERS CWP Reserved on 24.07.2024 SAHIB SINGH V/S UNION OF INDIA AND OTHERS CWP Reserved on 24.07.2024 ASHISH MAURYA V/S UNION OF INDIA AND OTHERS 46 and connected cases. CWP-13406-2024 (O&M) Reserved on 24.07.2024 ...Petitioner ......Respondents CWP-13607-2024 (O&M) Reserved on 24.07.2024 ...Petitioner DEPUTY COMMISSIONER OF INCOME TAX AND ORS......Respondents CWP-13608-2024 (O&M) Reserved on 24.07.2024 ...Petitioner ......Respondents CWP-13612-2024 (O&M) Reserved on 24.07.2024 ...Petitioner ......Respondents CWP-13632-2024 (O&M) Reserved on 24.07.2024 ...Petitioner ......Respondents s RAJESH KUMAR 2024.08.01 09:22 I attest to the accuracy and authenticity of this order/judgment. Punjab & Haryana High Court, Chandigarh. CWP-21509-2023 M/S JOSHI AUTOZONE PRIVATE LIMITED DEPUTY COMMISSIONER OF INCOME TAX CIR 1 CHANDIGARH AND ANR HANSA AGENCIES PVT LTD THROUGH ITS DIRECTOR NATIONAL FACELESS ASSESSMENT CENTRE DELHI AND OTHERS RAJESH MEHRU DEPUTY COMMISSIONER OF INCOME TAX, CENTRAL CIRCLE 2, AAYAKAR BHAWAN LUDHIANA SARABJIT SINGH DEPUTY COMMISSIONER OF INCOME TAX CENTRAL CIRCLE 2, AAYAKAR BHAWAN LUDHIANA YUVRAJ SINGH JOHAR UNION OF INDIA AND OTHERS Page 26 of 46 2023 (O&M) and connected cases. CWP Reserved on 24.07.2024 M/S JOSHI AUTOZONE PRIVATE LIMITED V/S DEPUTY COMMISSIONER OF INCOME TAX CIR 1 CHANDIGARH CWP Reserved on HANSA AGENCIES PVT LTD THROUGH ITS DIRECTOR V/S NATIONAL FACELESS ASSESSMENT CENTRE DELHI AND OTHERS CWP Reserved on 24.07.2024 RAJESH MEHRU V/S DEPUTY COMMISSIONER OF INCOME TAX, CENTRAL CIRCLE 2, AAYAKAR BHAWAN LUDHIANA CWP Reserved on 24.07.2024 SARABJIT SINGH V/S DEPUTY COMMISSIONER OF INCOME TAX CENTRAL CIRCLE 2, AAYAKAR BHAWAN LUDHIANA CWP Reserved on 24.07.2024 YUVRAJ SINGH JOHAR V/S UNION OF INDIA AND OTHERS 46 and connected cases. CWP-13633-2024(O&M) Reserved on 24.07.2024 M/S JOSHI AUTOZONE PRIVATE LIMITED ...Petitioner DEPUTY COMMISSIONER OF INCOME TAX CIR 1 CHANDIGARH ......Respondents CWP-13635-2024(O&M) Reserved on 24.07.2024 HANSA AGENCIES PVT LTD THROUGH ITS DIRECTOR ...Petitioner NATIONAL FACELESS ASSESSMENT CENTRE DELHI AND OTHERS ......Respondents CWP-13641-2024 (O&M) Reserved on 24.07.2024 ...Petitioner DEPUTY COMMISSIONER OF INCOME TAX, CENTRAL CIRCLE 2, ......Respondent CWP-13650-2024 (O&M) Reserved on 24.07.2024 ...Petitioner DEPUTY COMMISSIONER OF INCOME TAX CENTRAL CIRCLE 2, ......Respondent CWP-13651-2024 (O&M) Reserved on 24.07.2024 ...Petitioner ......Respondents DEPUTY COMMISSIONER OF INCOME TAX CIR 1 CHANDIGARH NATIONAL FACELESS ASSESSMENT CENTRE DELHI AND OTHERS DEPUTY COMMISSIONER OF INCOME TAX, CENTRAL CIRCLE 2, DEPUTY COMMISSIONER OF INCOME TAX CENTRAL CIRCLE 2, RAJESH KUMAR 2024.08.01 09:22 I attest to the accuracy and authenticity of this order/judgment. Punjab & Haryana High Court, Chandigarh. CWP-21509-2023 ARUN GUPTA UNION OF INDIA AND OTHERS RAJESH ARORA DEPUTY COMMISSION OF INCOME TAX ISGEC HEAVY ENGINEERING LTD YAMUNANAGAR UNION OF INDIA, MINISTRY OF FINANCE, DEPARTMENT OF REVENUE, THROUGH ITS SECRETARY ISGEC HEAVY ENGINEERING LTD, YAMUNANAGAR UNION OF INDIA, MINISTRY OF FINANCE, DEPARTMENT OF REVENUE, Page 27 of 46 2023 (O&M) and connected cases. CW Reserved on 24.07.2024 ARUN GUPTA V/S UNION OF INDIA AND OTHERS CWP Reserved on 24.07.2024 RAJESH ARORA V/S DEPUTY COMMISSION OF INCOME TAX CWP Reserved on 24.07.2024 ISGEC HEAVY ENGINEERING LTD YAMUNANAGAR V/S UNION OF INDIA, MINISTRY OF FINANCE, DEPARTMENT OF REVENUE, THROUGH ITS SECRETARY CWP Reserved on 24.07.2024 ISGEC HEAVY ENGINEERING LTD, YAMUNANAGAR V/S UNION OF INDIA, MINISTRY OF FINANCE, DEPARTMENT OF 46 and connected cases. CWP-13681-2024 (O&M) Reserved on 24.07.2024 ...Petitioner ......Respondents CWP-13686-2024 (O&M) Reserved on 24.07.2024 ...Petitioner DEPUTY COMMISSION OF INCOME TAX ......Respondent CWP-13687-2024 (O&M) Reserved on 24.07.2024 ISGEC HEAVY ENGINEERING LTD YAMUNANAGAR ...Petitioner UNION OF INDIA, MINISTRY OF FINANCE, DEPARTMENT OF ......Respondent CWP-13690-2024 (O&M) Reserved on 24.07.2024 ISGEC HEAVY ENGINEERING LTD, YAMUNANAGAR ...Petitioner UNION OF INDIA, MINISTRY OF FINANCE, DEPARTMENT OF ......Respondent UNION OF INDIA, MINISTRY OF FINANCE, DEPARTMENT OF UNION OF INDIA, MINISTRY OF FINANCE, DEPARTMENT OF RAJESH KUMAR 2024.08.01 09:22 I attest to the accuracy and authenticity of this order/judgment. Punjab & Haryana High Court, Chandigarh. CWP-21509-2023 ASHOK KUMAR HANDA UNION OF INDIA AND OTHERS VENUS COUNTRY DEVELOPERS PVT LTD DEPUTY COMMISSIONER OF INCOME TAX ORCHARD TOWNSHIP PRIVATE LIMITED DEPUTY COMMISSIONER OF INCOME TAX MUNISHA GANDHI PRINCIPAL COMMISSIONER OF INCOME TAX 1 AND ORS GORAV AGGARWAL DEPUTY COMMISSIONER OF INCOME TAX RAJINDER SINGH INCOME TAX OFFICER WARD 1 Page 28 of 46 2023 (O&M) and connected cases. CWP Reserved on ASHOK KUMAR HANDA V/S UNION OF INDIA AND OTHERS CWP Reserved on 24.07.2024 VENUS COUNTRY DEVELOPERS PVT LTD V/S DEPUTY COMMISSIONER OF INCOME TAX CWP Reserved on 24.07.2024 ORCHARD TOWNSHIP PRIVATE LIMITED V/S DEPUTY COMMISSIONER OF INCOME TAX CWP Reserved on 24.07.2024 MUNISHA GANDHI V/S PRINCIPAL COMMISSIONER OF INCOME TAX 1 AND ORS CWP Reserved on 24.07.2024 GORAV AGGARWAL V/S DEPUTY COMMISSIONER OF INCOME TAX CWP Reserved on 24.07.2024 RAJINDER SINGH V/S INCOME TAX OFFICER WARD 1 46 and connected cases. CWP-13697-2024 (O&M) Reserved on 24.07.2024 ...Petitioner ......Respondents CWP-13704-2024 (O&M) Reserved on 24.07.2024 VENUS COUNTRY DEVELOPERS PVT LTD ...Petitioner DEPUTY COMMISSIONER OF INCOME TAX ......Respondent CWP-13706-2024 (O&M) Reserved on 24.07.2024 ORCHARD TOWNSHIP PRIVATE LIMITED ...Petitioner DEPUTY COMMISSIONER OF INCOME TAX ......Respondent CWP-13722-2024 (O&M) Reserved on 24.07.2024 ...Petitioner PRINCIPAL COMMISSIONER OF INCOME TAX 1 AND ORS ......Respondents CWP-14130-2024 (O&M) Reserved on 24.07.2024 ...Petitioner DEPUTY COMMISSIONER OF INCOME TAX ......Respondent CWP-14133-2024 (O&M) Reserved on 24.07.2024 ...Petitioner ......Respondent RAJESH KUMAR 2024.08.01 09:22 I attest to the accuracy and authenticity of this order/judgment. Punjab & Haryana High Court, Chandigarh. CWP-21509-2023 SANTOSH SAHDEV UNION OF INDIA AND OTHERS NEETA GULATI INCOME TAX OFFICER WARD 1 BRAHMA CITY PRIVATE LIMITED DEPUTY COMMISSIONER OF INCOME TAX UNIQUE SURYVEYOS PVT LTD INCOME TAX OFFICER KRISHAN KU NATIONAL FACELESS ASSESSMENT CENTRE VIKRAM BHATIA NATIONAL FACELESS ASSESSMENT CENTRE AND OTHERS Page 29 of 46 2023 (O&M) and connected cases. CWP Reserved on 24.07.2024 SANTOSH SAHDEV V/S UNION OF INDIA AND OTHERS CWP Reserved on 24.07.2024 NEETA GULATI V/S INCOME TAX OFFICER WARD 1 CWP Reserved on 24.07.2024 BRAHMA CITY PRIVATE LIMITED V/S COMMISSIONER OF INCOME TAX CWP Reserved on 24.07.2024 UNIQUE SURYVEYOS PVT LTD V/S INCOME TAX OFFICER SANGRUR CWP Reserved on 24.07.2024 KRISHAN KUMAR AND SONS HUF V/S NATIONAL FACELESS ASSESSMENT CENTRE CWP Reserved on 24.07.2024 VIKRAM BHATIA V/S NATIONAL FACELESS ASSESSMENT CENTRE AND OTHERS 46 and connected cases. CWP-14216-2024 (O&M) Reserved on 24.07.2024 ...Petitioner ......Respondents CWP-14224-2024 (O&M) Reserved on 24.07.2024 ...Petitioner ......Respondent CWP-14227-2024 (O&M) Reserved on 24.07.2024 ...Petitioner COMMISSIONER OF INCOME TAX ......Respondent CWP-14231-2024(O&M) Reserved on 24.07.2024 ...Petitioner ......Respondent CWP-14077-2024 (O&M) Reserved on 24.07.2024 ...Petitioner NATIONAL FACELESS ASSESSMENT CENTRE ......Respondent CWP-14225-2024 (O&M) Reserved on 24.07.2024 ...Petitioner NATIONAL FACELESS ASSESSMENT CENTRE AND OTHERS ......Respondents RAJESH KUMAR 2024.08.01 09:22 I attest to the accuracy and authenticity of this order/judgment. Punjab & Haryana High Court, Chandigarh. CWP-21509-2023 AMIT GALHOTRA V/S INCOME TAX OFFICER AND ORS HERO CYCLES LTD V/S NATIONAL FACELESS ASSESSMENT CENTRE, DELHI M K PROTEINS LIMITED V/S INCOME TAX OFFICER AND OTHERS SANDEEP GARG V/S INCOME TAX GURDYAL PURI V/S INCOME TAX OFFICER AND ORS Page 30 of 46 2023 (O&M) and connected cases. CWP Reserved on 24.07.2024 AMIT GALHOTRA INCOME TAX OFFICER AND ORS CWP Reserved on 24.07.2024 HERO CYCLES LTD …Petitioner NATIONAL FACELESS ASSESSMENT CENTRE, DELHI …Respondent CWP Reserved on 24.07.2024 M K PROTEINS LIMITED INCOME TAX OFFICER AND OTHERS CWP Reserved on 24.07.2024 SANDEEP GARG INCOME TAX OFFICER AND ORS CWP Reserved on 24.07.2024 GURDYAL PURI INCOME TAX OFFICER AND ORS 46 and connected cases. CWP-14205-2024 Reserved on 24.07.2024 …Petitioner …Respondents CWP-8973-2024 Reserved on 24.07.2024 …Petitioner NATIONAL FACELESS ASSESSMENT CENTRE, DELHI AND ORS. …Respondents CWP-12751-2024 (O&M) Reserved on 24.07.2024 …Petitioner …Respondents CWP-12936-2024 (O&M) Reserved on 24.07.2024 …Petitioner …Respondents CWP-12944-2024 (O&M) Reserved on 24.07.2024 …Petitioner …Respondents RAJESH KUMAR 2024.08.01 09:22 I attest to the accuracy and authenticity of this order/judgment. Punjab & Haryana High Court, Chandigarh. CWP-21509-2023 SHREE SANATAN DHARAM SABHA V/S INCOME TAX OFFICER AND ORS A.D.H POLYMERS PVT LTD V/S INCOME TAX OFFICER AND ORS STALWART ALLOYS INDIA LTD V/S UNION OF INDIA AND OTHERS MOHINDER SINGH SANDHU THROUGH LRS SIMERJIT KAUR SANDHU V/S UNION OF INDIA AND ORS. CHARRUKH GOYAL V/S DEPUTY COMMISSIONER OF INCOME TAX AND OTHERS Page 31 of 46 2023 (O&M) and connected cases. CWP Reserved on 24.07.2024 SHREE SANATAN DHARAM SABHA INCOME TAX OFFICER AND ORS CWP Reserved on 24.07.2024 A.D.H POLYMERS PVT LTD INCOME TAX OFFICER AND ORS CWP Reserved on 24.07.2024 STALWART ALLOYS INDIA LTD UNION OF INDIA AND OTHERS CWP Reserved on 2 MOHINDER SINGH SANDHU THROUGH LRS SIMERJIT KAUR SANDHU …Petitioner UNION OF INDIA AND ORS. CWP Reserved on CHARRUKH GOYAL DEPUTY COMMISSIONER OF INCOME TAX AND OTHERS 46 and connected cases. CWP-12996-2024 (O&M) Reserved on 24.07.2024 …Petitioner …Respondents CWP-13031-2024 (O&M) Reserved on 24.07.2024 …Petitioner …Respondents CWP-14365-2024 (O&M) Reserved on 24.07.2024 …Petitioner …Respondents CWP-14838-2023 Reserved on 24.07.2024 MOHINDER SINGH SANDHU THROUGH LRS SIMERJIT …Respondents CWP-16345-2024 (O&M) Reserved on 25.07.2024 …Petitioner DEPUTY COMMISSIONER OF INCOME TAX AND OTHERS …Respondents MOHINDER SINGH SANDHU THROUGH LRS SIMERJIT RAJESH KUMAR 2024.08.01 09:22 I attest to the accuracy and authenticity of this order/judgment. Punjab & Haryana High Court, Chandigarh. CWP-21509-2023 DELTA ELECTRONICS INDIA PRIVATE LIMITED V/S ASSISTANT COMMISSONER OF INCOME TAX AND RAJIV KUMAR LOHIA V/S INCOME TAX OFFICER AND ORS GURINDER PAL SINGH V/S UNION OF INDIA AND OTHER RAMESH KUMAR V/S INCOME TAX OFFICER AND ORS M/S GOYAL LUBES V/S UNION OF INDIA AND OTHERS Page 32 of 46 2023 (O&M) and connected cases. CWP Reserved on 25.07.2024 DELTA ELECTRONICS INDIA PRIVATE LIMITED ASSISTANT COMMISSONER OF INCOME TAX AND CWP Reserved on 25.07.2024 RAJIV KUMAR LOHIA INCOME TAX OFFICER AND ORS CWP Reserved on 25.07.2024 GURINDER PAL SINGH UNION OF INDIA AND OTHER CWP Reserved on 25.07.2024 RAMESH KUMAR INCOME TAX OFFICER AND ORS CWP Reserved on 25.07.2024 M/S GOYAL LUBES UNION OF INDIA AND OTHERS 46 and connected cases. CWP-16357-2024 Reserved on 25.07.2024 DELTA ELECTRONICS INDIA PRIVATE LIMITED …Petitioner ASSISTANT COMMISSONER OF INCOME TAX AND ANOTHER …Respondents CWP-16507-2024 Reserved on 25.07.2024 …Petitioner …Respondents CWP-16509-2024 (O&M) Reserved on 25.07.2024 …Petitioner …Respondents CWP-16512-2024 (O&M) Reserved on 25.07.2024 …Petitioner …Respondents CWP-16515-2024 (O&M) Reserved on 25.07.2024 …Petitioner …Respondents RAJESH KUMAR 2024.08.01 09:22 I attest to the accuracy and authenticity of this order/judgment. Punjab & Haryana High Court, Chandigarh. CWP-21509-2023 HARVINDER SINGH V/S INCOME TAX OFFICER AND OTHERS MADHVI GUJRAL V/S INCOME TAX OFFICER AND ORS KRISHAN KUMAR V/S INCOME TAX OFFICER AND OTHERS INDER KUMAR V/S INCOME TAX OFFICER AND OTHER RED CHILLI INTERNATIONAL SALES V/S INCOME TAX OFFICER AND ANOTHER Page 33 of 46 2023 (O&M) and connected cases. CWP Reserved on 25.07.2024 HARVINDER SINGH INCOME TAX OFFICER AND OTHERS CWP Reserved on 25.07.2024 MADHVI GUJRAL INCOME TAX OFFICER AND ORS CWP Reserved on 25.07.2024 KRISHAN KUMAR INCOME TAX OFFICER AND OTHERS CWP Reserved on 25.07.2024 INDER KUMAR INCOME TAX OFFICER AND OTHER CWP Reserved on 25.07.2024 RED CHILLI INTERNATIONAL SALES INCOME TAX OFFICER AND ANOTHER 46 and connected cases. CWP-16665-2024 (O&M) Reserved on 25.07.2024 …Petitioner …Respondents CWP-16687-2024 (O&M) Reserved on 25.07.2024 …Petitioner …Respondents CWP-17321-2024 (O&M) Reserved on 25.07.2024 …Petitioner …Respondents CWP-17327-2024 (O&M) Reserved on 25.07.2024 …Petitioner …Respondents CWP-10073-2022 (O&M) Reserved on 25.07.2024 …Petitioner …Respondents RAJESH KUMAR 2024.08.01 09:22 I attest to the accuracy and authenticity of this order/judgment. Punjab & Haryana High Court, Chandigarh. CWP-21509-2023 M/S SHANKESHWAR ENTERPRISES V/S INCOME TAX OFFICER AND OTHERS CORAM: HON’BLE MR. JUSTICE SANJEEV PRAKASH SHARMA HON’BLE MR. JUSTICE Present: Mr. Sanjay Bansal, Sr. Advocate with Mr. Gurdeep Singh, Ms. Radhika Suri, Sr. Advocate with Mr. Abhinav Narang, Advocate, Mr. Akshay Bhan, Sr. Advocate with Mr. Shantanu Bansal, Advocate and Mr. Yugank Goyal, Advocate Mr. Sandeep Goyal, Advocate, Mr. Nikhil Goyal, Advocate, Mr. Rana Gurtej Mr. Vaibhav Sharma, Advocate Mr. Adarsh Dubey, Advocate, Mr. Sandeep Wadhawan, Advocate, Mr. Abhishak Sharma, Advocate, Mr. Vishal Gupta, Advocate, Mr. Viren Sharma, Advocate, Mr. Alok Mittal, Advocate Mr. Chetan Jain, Advocate, Mr. Umang Goyal, Advocate, Mr. Tarun Chanana, Advocate, Mr. Salil Kapoor, Advocate, Mr. Amrinder Singh, Advocate, Mr. Sholab Arora, Advocate, Mr. B.M. Monga, Advocate, Mr. Chetan Jain, Advocate, Mr. Aditya Dassuar, Advocate, Mr. Kamal Kumar Gupta, Mr. Nitin Bhasin, Advocate, Mr. Rohit Kaura, Advocate, Mr. Rajiv Sharma, Advocate, Mr. Puneet Kansal, Advocate Mr. Sunil K. Mukhi, Advocate, Mr. Prince Goyal, Advocate Mr. Viren Sharma, Advocate, Ms. Salina Chalana, Advocate, Page 34 of 46 2023 (O&M) and connected cases. CWP Reserved on 25.07.2024 M/S SHANKESHWAR ENTERPRISES INCOME TAX OFFICER AND OTHERS HON’BLE MR. JUSTICE SANJEEV PRAKASH SHARMA HON’BLE MR. JUSTICE SANJAY VASHISTH Mr. Sanjay Bansal, Sr. Advocate with Mr. Gurdeep Singh, Advocate, Ms. Radhika Suri, Sr. Advocate with Mr. Abhinav Narang, Advocate, Mr. Akshay Bhan, Sr. Advocate with Mr. Shantanu Bansal, Advocate and Mr. Yugank Goyal, Advocate Mr. Sandeep Goyal, Advocate, Mr. Nikhil Goyal, Advocate, Mr. Rana Gurtej Singh, Advocate, Mr. Vaibhav Sharma, Advocate Mr. Adarsh Dubey, Advocate, Mr. Sandeep Wadhawan, Advocate, Mr. Abhishak Sharma, Advocate, Mr. Vishal Gupta, Advocate, Mr. Viren Sharma, Advocate, Mr. Alok Mittal, Advocate Mr. Chetan Jain, Advocate, Mr. Umang Goyal, Advocate, Mr. Tarun Chanana, Advocate, Mr. Salil Kapoor, Advocate, Mr. Amrinder Singh, Advocate, Mr. Sholab Arora, Advocate, Mr. B.M. Monga, Advocate, Mr. Chetan Jain, Advocate, Mr. Aditya Dassuar, Advocate, Mr. Kamal Kumar Gupta, Advocate, Mr. Nitin Bhasin, Advocate, Mr. Rohit Kaura, Advocate, Mr. Rajiv Sharma, Advocate, Mr. Puneet Kansal, Advocate Mr. Sunil K. Mukhi, Advocate, Mr. Prince Goyal, Advocate, Mr. Viren Sharma, Advocate, Ms. Salina Chalana, Advocate, 46 and connected cases. CWP-14782-2024 (O&M) Reserved on 25.07.2024 …Petitioner …Respondents HON’BLE MR. JUSTICE SANJEEV PRAKASH SHARMA SANJAY VASHISTH Mr. Sanjay Bansal, Sr. Advocate with Ms. Radhika Suri, Sr. Advocate with Mr. Abhinav Narang, Advocate, Mr. Akshay Bhan, Sr. Advocate with Mr. Shantanu Bansal, Advocate and Singh, Advocate, Mr. Sandeep Wadhawan, Advocate, Mr. Abhishak Sharma, Advocate, Advocate, RAJESH KUMAR 2024.08.01 09:22 I attest to the accuracy and authenticity of this order/judgment. Punjab & Haryana High Court, Chandigarh. CWP-21509-2023 Mr. Manpreet Kand Mr. Rohit Sud, Advocate, Ms. Kuljeet Kaur, Advocate, Mr. Sachin Bhardwaj, Advocate, Mr. Aman Garg, Advocate, Mr. Kapish Chawla, Advocate, Mr. Divya Suri, Advocate, Mr. Peyush Pruthi, Advocate, Mr. Tejinder Joshi, Advocate, Mr. Siddhant Koh Mr. Kushagra Mahajan, Advocate Mr. Amit Kumar Gupta, Advocate, Mr. Prateek, Advocate, Mr. Varun Sharma, Advocate and Mr. Rajiv Sharma, Advocate for the petitioner(s). Mr. Saurabh Kapoor, in CWP 12751 Mr. Ashutosh, Advocate for Ms. Urvashi Dhugga, Sr. Panel Counsel for Income Tax Department in CWP 13 2024 Mr. Vaibhav Gupta, Advocate for the revenue. Mr. Yogesh Putney, Department in CWP 17513 2024, CWP CWP 11519 12366 12796 13612 13651 13722 Ms. Gauri Neo Rampal, Sr. Standing Counsel for the respondents in CWP CWP CWP CWP CWP CWP CWP CWP Page 35 of 46 2023 (O&M) and connected cases. Mr. Manpreet Kanda, Advocate, Mr. Rohit Sud, Advocate, Ms. Kuljeet Kaur, Advocate, Mr. Sachin Bhardwaj, Advocate, Mr. Aman Garg, Advocate, Mr. Kapish Chawla, Advocate, Mr. Divya Suri, Advocate, Mr. Peyush Pruthi, Advocate, Mr. Tejinder Joshi, Advocate, Mr. Siddhant Kohli, Advocate, Mr. Kushagra Mahajan, Advocate Mr. Amit Kumar Gupta, Advocate, Mr. Prateek, Advocate, Mr. Varun Sharma, Advocate and Mr. Rajiv Sharma, Advocate for the petitioner(s). Mr. Saurabh Kapoor, Sr. Standing Counsel in CWP-8667-2024, CWP-8668- 12751-2024, CWP-13608-2024, CWP Mr. Ashutosh, Advocate for Ms. Urvashi Dhugga, Sr. Panel Counsel for Income Tax Department in CWP-10964-2024, 13406 13679-2024, 13635-2024, 1422 2024 and 12736-2024. Mr. Vaibhav Gupta, Advocate for the revenue. Mr. Yogesh Putney, Sr. Standing Counsel Department in CWP-14062-2023, CWP 17513-2023, CWP-23128-2023, CWP 2024, CWP-8513-2024, CWP- CWP-10977-2024, CWP-11354- 11519-2024, CWP-11783-2024, CWP 12366-2024, CWP-12579-2024, CWP 12796-2024, CWP-12867-2024, 13612-2024, CWP-13632-2024, CWP 13651-2024, CWP-13705-2024, CWP 13722-2024. Ms. Gauri Neo Rampal, Sr. Standing Counsel for the respondents in CWP-12198 CWP-13869-2023, CWP-13870 CWP-13872-2023, CWP-13874 CWP-13878-2023, CWP-13879 CWP-13886-2023, CWP-13919 CWP-13987-2023, CWP-13991 CWP-14074-2023, CWP-14108 CWP-14179-2023, CWP-14184 46 and connected cases. Mr. Sachin Bhardwaj, Advocate, Mr. Kushagra Mahajan, Advocate, Mr. Amit Kumar Gupta, Advocate, Mr. Varun Sharma, Advocate and Sr. Standing Counsel for the respondents -2024, CWP-12743-2024, CWP- 2024, CWP-12750-2024. for Ms. Urvashi Dhugga, Sr. Panel Counsel for Income Tax 2024, 13406-2024, 13686-2024, 2024, 14227-2024, 13348-2024, 14077- Mr. Vaibhav Gupta, Advocate for the revenue. Sr. Standing Counsel for the Income Tax 2023, CWP-15963-2023, CWP- 3, CWP-23187-2023, CWP-5011- -8519-2024, CWP-10404-2024, -2024, CWP-11517-2024, CWP- 2024, CWP-12048-2024, CWP- 2024, CWP-12740-2024, CWP- 2024, CWP-13607-2024, CWP- 2024, CWP-13633-2024, CWP- 2024, CWP-13031-2024 and CWP- Ms. Gauri Neo Rampal, Sr. Standing Counsel for the 12198-2023, CWP-12199-2023, 13870-2023, CWP-13871-2023, 13874-2023, CWP-13875-2023, 13879-2023, CWP-13881-2023, 13919-2023, CWP-13935-2023, 13991-2023, CWP-14045-2023, 108-2023, CWP-14124-2023, 14184-2023, CWP-14202-2023, for the respondents - for Ms. Urvashi Dhugga, Sr. Panel Counsel for Income Tax 2024, - for the Income Tax - - 2024, - - - - - - Ms. Gauri Neo Rampal, Sr. Standing Counsel for the 2023, 2023, 2023, 2023, 2023, 2023, 2023, 2023, RAJESH KUMAR 2024.08.01 09:22 I attest to the accuracy and authenticity of this order/judgment. Punjab & Haryana High Court, Chandigarh. CWP-21509-2023 CWP CWP CWP CWP Mr. Amanpreet respondents. Mr. Sourabh Kapoor, Ms. Pridhi Sandhu, Junior Standing Counsel for Income Tax Department in CWP 14345 Mr. Ranvijay Singh, CWP 9264, 9570, 4211, 10978, 10568, 11232, 11659, 11661, 12370, 12371, 11949, 12360 and 8974 of 2024 SANJEEV PRAKASH SHARMA 1. Th ‘as to whether the Jurisdictional Assessing Officer (hereinafter referred to as ‘the JAO’) is empowered to issue notice under Section 148 of the Income Tax Act, 1961 (hereinafter referred to as ‘the Act, 1961’), after the regime of faceless assessment has been brought into force by the amendment made under Section 148 of the Act, 1961. 2. In the bunch of these writ petition, admittedly notice was issued by the JAO for re passed under Section 151 of the Act, 1961, have also been impugned. 3. The challenge in most of the cases is the ground that it should have been issued by the National Faceless Assessment Centre and the proceedings also ought to have been condu terms of notification dated 29.03.2022. This Court passed interim order restraining the respondents from passing any final order. Page 36 of 46 2023 (O&M) and connected cases. CWP-14206-2023, CWP-14695 CWP-7640-2023, CWP-13133 CWP-23292-2023, CWP-23293 CWP-23342-2023 Mr. Amanpreet (A.P.) Singh, respondents. Mr. Sourabh Kapoor, Sr. Standing Counsel Ms. Pridhi Sandhu, Junior Standing Counsel for Income Tax Department in CWP-13679-2024, CWP 14345-2024, CWP-9662-2024 and Mr. Ranvijay Singh, Sr. Standing Counsel CWP-12714, 22645, 12770, 12888, 12916 of 2023, 9422, 9252, 9264, 9570, 4211, 10978, 10568, 11232, 11659, 11661, 12370, 12371, 11949, 12360 and 8974 of 2024 *** SANJEEV PRAKASH SHARMA, J. These bunch of writ petitions raise common question of law that ‘as to whether the Jurisdictional Assessing Officer (hereinafter referred to as ‘the JAO’) is empowered to issue notice under Section 148 of the Income Tax Act, 1961 (hereinafter referred to as ‘the Act, 1961’), after the regime of faceless assessment has been brought into force by the amendment made under Section 148 of the Act, 1961. In the bunch of these writ petition, admittedly notice was issued by the JAO for re-assessment after 01.04.2021 and further appro passed under Section 151 of the Act, 1961, have also been impugned. The challenge in most of the cases is the ground that it should have been issued by the National Faceless Assessment Centre and the proceedings also ought to have been condu terms of notification dated 29.03.2022. This Court passed interim order restraining the respondents from passing any final order. 46 and connected cases. 14695-2023, CWP-23318-2023, 13133-2023, CWP-13147-2023, 23293-2023, CWP-23324-2023 and (A.P.) Singh, Sr. Standing Counsel for the Sr. Standing Counsel with Ms. Pridhi Sandhu, Junior Standing Counsel for Income Tax 2024, CWP-13697-2024, CWP- 2024 and CWP-12743-2024. Sr. Standing Counsel for the respondents in 12714, 22645, 12770, 12888, 12916 of 2023, 9422, 9252, 9264, 9570, 4211, 10978, 10568, 11232, 11659, 11661, 12370, 12371, 11949, 12360 and 8974 of 2024. raise common question of law that ‘as to whether the Jurisdictional Assessing Officer (hereinafter referred to as ‘the JAO’) is empowered to issue notice under Section 148 of the Income Tax Act, 1961 (hereinafter referred to as ‘the Act, 1961’), after the new regime of faceless assessment has been brought into force by the amendment In the bunch of these writ petition, admittedly notice was issued assessment after 01.04.2021 and further approval order passed under Section 151 of the Act, 1961, have also been impugned. The challenge in most of the cases is the ground that it should have been issued by the National Faceless Assessment Centre and the proceedings also ought to have been conducted by the same authority in terms of notification dated 29.03.2022. This Court passed interim order restraining the respondents from passing any final order. 2023, 2023, 2023 and for the Ms. Pridhi Sandhu, Junior Standing Counsel for Income Tax - for the respondents in 12714, 22645, 12770, 12888, 12916 of 2023, 9422, 9252, 9264, 9570, 4211, 10978, 10568, 11232, 11659, 11661, 12370, raise common question of law that ‘as to whether the Jurisdictional Assessing Officer (hereinafter referred to as ‘the JAO’) is empowered to issue notice under Section 148 of the Income new regime of faceless assessment has been brought into force by the amendment In the bunch of these writ petition, admittedly notice was issued val order The challenge in most of the cases is the ground that it should have been issued by the National Faceless Assessment Centre and the cted by the same authority in terms of notification dated 29.03.2022. This Court passed interim order RAJESH KUMAR 2024.08.01 09:22 I attest to the accuracy and authenticity of this order/judgment. Punjab & Haryana High Court, Chandigarh. CWP-21509-2023 4. Learned counsel attention to the fact that the i Coordinate Bench vide its judgment pronounced on 19.07.2024, in CWP 15745-2024 and CWP 5. Per contra certain aspects have not been considere considered by this Court, the same would result in a different interpretation. 6. In order to maintain judicial discipline and consistency, this Court would follow the judgment rendered by the Coordinate Bench (supra). However, as the learned counsel for the revenue had made further contentions, it would be in the interest of justice and to maintain the principle of right for hearing to the parties, after the notices had already been issued in these cases, we have heard through the judgment passed by the Coordinate Bench. 7. Learned counsels appearing for the revenue state that the office memorandum issued on 20.02.2023 and the order dated 19.01.2024, were neither challenged by any of the assessees in the proceedings nor it can be said to be overwriting the statutory provisions and submit that the orders have been issued keeping in view the provisions contained Act, 1961, which only refers to the assessment shall be done and does not exclude the power to issue notice under Section 148 of the Act, 1961 by the JAO. Mr. Putney, learned Senior Standing Counsel has argued that Section 119 of the Act, 1961, empowers instructions as have been issued vide office memorandum dated 20.02.2023 and circular dated 19.01.2024. He submits that the cases type high Page 37 of 46 2023 (O&M) and connected cases. Learned counsel appearing for the attention to the fact that the issue stands already adjudicated finally by the Coordinate Bench vide its judgment pronounced on 19.07.2024, in CWP 2024 and CWP-15791-2024. Per contra, it is the contention of counsel for the revenue that certain aspects have not been considered by the Coordinate Bench, which if considered by this Court, the same would result in a different interpretation. In order to maintain judicial discipline and consistency, this Court would follow the judgment rendered by the Coordinate Bench (supra). However, as the learned counsel for the revenue had made further contentions, it would be in the interest of justice and to maintain the principle of right for hearing to the parties, after the notices had already been issued in cases, we have heard the respective counsels and have respectfully gone through the judgment passed by the Coordinate Bench. Learned counsels appearing for the revenue state that the office memorandum issued on 20.02.2023 and the order dated 19.01.2024, were lenged by any of the assessees in the proceedings nor it can be said to be overwriting the statutory provisions and submit that the orders have been issued keeping in view the provisions contained Act, 1961, which only refers to the method and manner in which faceless assessment shall be done and does not exclude the power to issue notice under Section 148 of the Act, 1961 by the JAO. Mr. Putney, learned Senior Standing Counsel has argued that Section 119 of the Act, 1961, empowers the board to issue such orders and instructions as have been issued vide office memorandum dated 20.02.2023 and circular dated 19.01.2024. He submits that the cases type high 46 and connected cases. appearing for the petitioners have invited ssue stands already adjudicated finally by the Coordinate Bench vide its judgment pronounced on 19.07.2024, in CWP- , it is the contention of counsel for the revenue that d by the Coordinate Bench, which if considered by this Court, the same would result in a different interpretation. In order to maintain judicial discipline and consistency, this Court would follow the judgment rendered by the Coordinate Bench (supra). However, as the learned counsel for the revenue had made further contentions, it would be in the interest of justice and to maintain the principle of right for hearing to the parties, after the notices had already been issued in the respective counsels and have respectfully gone through the judgment passed by the Coordinate Bench. Learned counsels appearing for the revenue state that the office memorandum issued on 20.02.2023 and the order dated 19.01.2024, were lenged by any of the assessees in the proceedings nor it can be said to be overwriting the statutory provisions and submit that the orders have been issued keeping in view the provisions contained in Section 144B of the method and manner in which faceless assessment shall be done and does not exclude the power to issue notice under Section 148 of the Act, 1961 by the JAO. Mr. Putney, learned Senior Standing Counsel has argued that the board to issue such orders and instructions as have been issued vide office memorandum dated 20.02.2023 and circular dated 19.01.2024. He submits that the cases type high have invited ssue stands already adjudicated finally by the - , it is the contention of counsel for the revenue that d by the Coordinate Bench, which if In order to maintain judicial discipline and consistency, this Court would follow the judgment rendered by the Coordinate Bench (supra). However, as the learned counsel for the revenue had made further contentions, it would be in the interest of justice and to maintain the principle of right for hearing to the parties, after the notices had already been issued in the respective counsels and have respectfully gone Learned counsels appearing for the revenue state that the office memorandum issued on 20.02.2023 and the order dated 19.01.2024, were lenged by any of the assessees in the proceedings nor it can be said to be overwriting the statutory provisions and submit that the orders have Section 144B of the method and manner in which faceless assessment shall be done and does not exclude the power to issue notice Mr. Putney, learned Senior Standing Counsel has argued that the board to issue such orders and instructions as have been issued vide office memorandum dated 20.02.2023 and circular dated 19.01.2024. He submits that the cases type high RAJESH KUMAR 2024.08.01 09:22 I attest to the accuracy and authenticity of this order/judgment. Punjab & Haryana High Court, Chandigarh. CWP-21509-2023 CRUI/VRU information have been assigned to the JAO as cases relating to search and seizure ought to be looked into and examined by the JAO for the purpose of issuing of notice under Section 148 of the Act, 1961. It is his submission that after considering the scope of the scheme as notified in 2022, the Government of India had issued the scope and power as avail Section 120 of the Act, 1961, which authorities to issue instructions, Bench while deciding the cases (supra) and this Court ought to examine the same. 8. Learned counsel for the petitioners on the other hand submit that the very purpose of providing faceless assessment scheme, would stand negated if the respond Sections 119 and 120 of the Act, 1961, to issue circulars or orders resulting in the amendments made in Sections 148 and 144B of the Act, 1961, as redundant. It is submitted that the powers contained Section 120B will have to be inconformity with the scheme of the Act. 9. We have considered the submissions. 10. The Coordinate Bench after noticing the judgments passed by the Division Bench of the Tele Courts passed the order in CWP Court has also considered the provisions contained under Section 148, 151A of the Act, 1961 and the e dated 29.03.2022. The Cen under Section 151A of the Act, 1961, had introduced the e Income Escaping Assessments Scheme 2022, which as per Section 3 Page 38 of 46 2023 (O&M) and connected cases. CRUI/VRU information have been assigned to the JAO as cases relating to nd seizure ought to be looked into and examined by the JAO for the purpose of issuing of notice under Section 148 of the Act, 1961. It is his submission that after considering the scope of the scheme as notified in 2022, the Government of India had issued the office memorandum. He submits that the scope and power as available under the aforesaid provisions as also under Section 120 of the Act, 1961, which expresses to issue instructions, has not been considered by the Bench while deciding the cases (supra) and this Court ought to examine the Learned counsel for the petitioners on the other hand submit that the very purpose of providing faceless assessment scheme, would stand negated if the respondents are allowed to use the power available under Sections 119 and 120 of the Act, 1961, to issue circulars or orders resulting in the amendments made in Sections 148 and 144B of the Act, 1961, as redundant. It is submitted that the powers contained Section 120B will have to be inconformity with the scheme of the Act. We have considered the submissions. The Coordinate Bench after noticing the judgments passed by the Division Bench of the Telengana, Calcutta, Bombay and Courts passed the order in CWP-15745-2024 and CWP Court has also considered the provisions contained under Section 148, 151A of the Act, 1961 and the e-assessment scheme introduced vide notification dated 29.03.2022. The Central Government in terms of powers conferred under Section 151A of the Act, 1961, had introduced the e Income Escaping Assessments Scheme 2022, which as per Section 3 46 and connected cases. CRUI/VRU information have been assigned to the JAO as cases relating to nd seizure ought to be looked into and examined by the JAO for the purpose of issuing of notice under Section 148 of the Act, 1961. It is his submission that after considering the scope of the scheme as notified in 2022, the office memorandum. He submits that under the aforesaid provisions as also under expresses jurisdiction of income tax has not been considered by the Coordinate Bench while deciding the cases (supra) and this Court ought to examine the Learned counsel for the petitioners on the other hand submit that the very purpose of providing faceless assessment scheme, would stand ents are allowed to use the power available under Sections 119 and 120 of the Act, 1961, to issue circulars or orders resulting in the amendments made in Sections 148 and 144B of the Act, 1961, as redundant. It is submitted that the powers contained in Section 119 or under Section 120B will have to be inconformity with the scheme of the Act. We have considered the submissions. The Coordinate Bench after noticing the judgments passed by ngana, Calcutta, Bombay and Guwahati High 2024 and CWP-15791-2024. This Court has also considered the provisions contained under Section 148, 151A assessment scheme introduced vide notification tral Government in terms of powers conferred under Section 151A of the Act, 1961, had introduced the e-assessment of Income Escaping Assessments Scheme 2022, which as per Section 3 CRUI/VRU information have been assigned to the JAO as cases relating to nd seizure ought to be looked into and examined by the JAO for the purpose of issuing of notice under Section 148 of the Act, 1961. It is his submission that after considering the scope of the scheme as notified in 2022, the office memorandum. He submits that under the aforesaid provisions as also under jurisdiction of income tax Coordinate Bench while deciding the cases (supra) and this Court ought to examine the Learned counsel for the petitioners on the other hand submit that the very purpose of providing faceless assessment scheme, would stand ents are allowed to use the power available under Sections 119 and 120 of the Act, 1961, to issue circulars or orders resulting in the amendments made in Sections 148 and 144B of the Act, 1961, as Section 119 or under The Coordinate Bench after noticing the judgments passed by ati High 2024. This Court has also considered the provisions contained under Section 148, 151A assessment scheme introduced vide notification tral Government in terms of powers conferred assessment of Income Escaping Assessments Scheme 2022, which as per Section 3 RAJESH KUMAR 2024.08.01 09:22 I attest to the accuracy and authenticity of this order/judgment. Punjab & Haryana High Court, Chandigarh. CWP-21509-2023 mandated assessment, re of the Act and issuance of notice under Section 148 of the Act through automatic allocation. The Coordinate Bench has already considered the provision and passed the following order: 15. From the perusal of Section 151A, it is quite evident that scheme of fa show cause notice under Section 148 as well as 148A. Clause 3 (b) of notification dated 29.03.2022 issued under Section 151A clearly provides that scheme would be applicable to notice under Section 148. Eve that assessment proceedings commence from the stage of issuance of show cause notice. The object of introduction of faceless assessment would be defeated if show cause notice under Section 148 is issued by Ju The respondents are heavily placing reliance upon office memorandum and letter issued by departmental authorities. It is axiomatic intax jurisprudence that circulars, instructions and letters issued by Board or any other aut statutory provisions. The circulars are binding upon authorities and Courts are not bound by circulars. The mandate of Section 144B, 151A read with notification dated 29.03.2022 issued thereunder is quite lucid. There is no ambiguity of statutory provisions, thus, office memorandum or any other instruction issued by Board or any other authority cannot be relied upon. Instructions/circulars can supplement but cannot supplant statutory provisions. Page 39 of 46 2023 (O&M) and connected cases. mandated assessment, re-assessment and re-computation under Section 147 the Act and issuance of notice under Section 148 of the Act through automatic allocation. The Coordinate Bench has already considered the provision and passed the following order:- 15. From the perusal of Section 151A, it is quite evident that scheme of faceless assessment is applicable from the stage of show cause notice under Section 148 as well as 148A. Clause 3 (b) of notification dated 29.03.2022 issued under Section 151A clearly provides that scheme would be applicable to notice under Section 148. Even otherwise, it is a settled proposition of law that assessment proceedings commence from the stage of issuance of show cause notice. The object of introduction of faceless assessment would be defeated if show cause notice under Section 148 is issued by Ju The respondents are heavily placing reliance upon office memorandum and letter issued by departmental authorities. It is axiomatic intax jurisprudence that circulars, instructions and letters issued by Board or any other aut statutory provisions. The circulars are binding upon authorities and Courts are not bound by circulars. The mandate of Section 144B, 151A read with notification dated 29.03.2022 issued thereunder is quite lucid. There is no ambiguity of statutory provisions, thus, office memorandum or any other instruction issued by Board or any other authority cannot be relied upon. Instructions/circulars can supplement but cannot supplant statutory provisions. 46 and connected cases. computation under Section 147 the Act and issuance of notice under Section 148 of the Act through automatic allocation. The Coordinate Bench has already considered the 15. From the perusal of Section 151A, it is quite evident that celess assessment is applicable from the stage of show cause notice under Section 148 as well as 148A. Clause 3 (b) of notification dated 29.03.2022 issued under Section 151A clearly provides that scheme would be applicable to notice under n otherwise, it is a settled proposition of law that assessment proceedings commence from the stage of issuance of show cause notice. The object of introduction of faceless assessment would be defeated if show cause notice under Section 148 is issued by Jurisdictional Assessing Officer. The respondents are heavily placing reliance upon office memorandum and letter issued by departmental authorities. It is axiomatic intax jurisprudence that circulars, instructions and letters issued by Board or any other authority cannot override statutory provisions. The circulars are binding upon authorities and Courts are not bound by circulars. The mandate of Section 144B, 151A read with notification dated 29.03.2022 issued thereunder is quite lucid. There is no ambiguity in the language of statutory provisions, thus, office memorandum or any other instruction issued by Board or any other authority cannot be relied upon. Instructions/circulars can supplement but cannot computation under Section 147 the Act and issuance of notice under Section 148 of the Act through automatic allocation. The Coordinate Bench has already considered the 15. From the perusal of Section 151A, it is quite evident that celess assessment is applicable from the stage of show cause notice under Section 148 as well as 148A. Clause 3 (b) of notification dated 29.03.2022 issued under Section 151A clearly provides that scheme would be applicable to notice under n otherwise, it is a settled proposition of law that assessment proceedings commence from the stage of issuance of show cause notice. The object of introduction of faceless assessment would be defeated if show cause notice risdictional Assessing Officer. The respondents are heavily placing reliance upon office memorandum and letter issued by departmental authorities. It is axiomatic intax jurisprudence that circulars, instructions and hority cannot override statutory provisions. The circulars are binding upon authorities and Courts are not bound by circulars. The mandate of Section 144B, 151A read with notification dated 29.03.2022 issued in the language of statutory provisions, thus, office memorandum or any other instruction issued by Board or any other authority cannot be relied upon. Instructions/circulars can supplement but cannot RAJESH KUMAR 2024.08.01 09:22 I attest to the accuracy and authenticity of this order/judgment. Punjab & Haryana High Court, Chandigarh. CWP-21509-2023 16. In the wake of appropriate to subscribe view expressed by Bombay, Telangana and Gauhati High Court. The instant petitions deserve to be allowed and accordingly allowed. 17. The notices issued by Jurisdictional Assessing Officer u Section 148 are hereby quashed with liberty to respondent to proceed in accordance with procedure prescribed by law. 11. Section 119 of the Act, 1961, provides as under: “119. (1) The Board may, from time to instructions and directions to other income may deem fit for the proper administration of this Act, and such authorities and all other persons employed in the execution of this Act shall observe and follow su directions of the Board. Provided that no such orders, instructions or directions shall be issued. (2) Page 40 of 46 2023 (O&M) and connected cases. 16. In the wake of above discussion and findings, we find it appropriate to subscribe view expressed by Bombay, Telangana and Gauhati High Court. The instant petitions deserve to be allowed and accordingly allowed. 17. The notices issued by Jurisdictional Assessing Officer u Section 148 are hereby quashed with liberty to respondent to proceed in accordance with procedure prescribed by law. Section 119 of the Act, 1961, provides as under: “119. Instructions to subordinate authoritie (1) The Board may, from time to instructions and directions to other income may deem fit for the proper administration of this Act, and such authorities and all other persons employed in the execution of this Act shall observe and follow su directions of the Board. Provided that no such orders, instructions or directions shall be issued. (a) so as to require any income particular assessment or to dispose of a particular case in a particular manner:- (b) so as to interfere with the discretion of the Commissioner (Appeals) in the exercise of his appellate functions. (2) Without prejudice to the generality of the foregoing power. (a) the Board may, if it considers it necessary or expedient so to do, for the purpose of proper and efficient management of the work of assessment and collection of 46 and connected cases. above discussion and findings, we find it appropriate to subscribe view expressed by Bombay, Telangana and Gauhati High Court. The instant petitions deserve to be allowed and accordingly allowed. 17. The notices issued by Jurisdictional Assessing Officer under Section 148 are hereby quashed with liberty to respondent to proceed in accordance with procedure prescribed by law. Section 119 of the Act, 1961, provides as under:- Instructions to subordinate authorities:- (1) The Board may, from time to time, issue such orders, instructions and directions to other income-tax authorities as it may deem fit for the proper administration of this Act, and such authorities and all other persons employed in the execution of this Act shall observe and follow such orders, instructions and Provided that no such orders, instructions or directions shall be (a) so as to require any income-tax authority to make a particular assessment or to dispose of a particular case in a (b) so as to interfere with the discretion of the Commissioner (Appeals) in the exercise of his appellate Without prejudice to the generality of the foregoing power. (a) the Board may, if it considers it necessary or expedient to do, for the purpose of proper and efficient management of the work of assessment and collection of above discussion and findings, we find it appropriate to subscribe view expressed by Bombay, Telangana and Gauhati High Court. The instant petitions deserve to be nder Section 148 are hereby quashed with liberty to respondent to time, issue such orders, tax authorities as it may deem fit for the proper administration of this Act, and such authorities and all other persons employed in the execution of ch orders, instructions and Provided that no such orders, instructions or directions shall be tax authority to make a particular assessment or to dispose of a particular case in a (b) so as to interfere with the discretion of the Commissioner (Appeals) in the exercise of his appellate (a) the Board may, if it considers it necessary or expedient to do, for the purpose of proper and efficient management of the work of assessment and collection of RAJESH KUMAR 2024.08.01 09:22 I attest to the accuracy and authenticity of this order/judgment. Punjab & Haryana High Court, Chandigarh. CWP-21509-2023 Page 41 of 46 2023 (O&M) and connected cases. revenue, issue, from time to time (whether by way of relaxation of any of the provisions of sections 3[115P, 115S, 115WD, 115WE, 115WF, 115WG, 115WH, 115WJ, 115WK,] [139,] 143, 144, 147, 148, 154, 155[158BFA], [sub-section (1A) of section 201, sections 210, 211, 234A, 234B, 234C [234E], [270A,] 271 [271C, 271CA] and 273 or otherwise), general or special orders in respect of [any class of incomes or fringe class of cases, setting forth directions or instructions (not being prejudicial to assessees) as to the guidelines, principles or procedures to be followed by other income tax authorities in the work relating to assessment or collection of revenue or the initiation of proceedings for the imposition of penalties and any such order may, if the Board is of opinion that it is necessary in the public interest so to do, be published and circulated in the prescribed manner for general information; (b) the Board may, if it considers it desirable or expedient so to do for avoiding genuine hardship in any case or class of cases, by general or special order, authorise [any income-tax authority, not being a Commissioner (Appeals)] to admit an application or exemption, deduction, refund or any other relief under this Act after the expiry of the period specified by or under this Act for making such application or claim and deal with the same on merits in accordance with law; 46 and connected cases. revenue, issue, from time to time (whether by way of relaxation of any of the provisions of sections 3[115P, 115S, 115WD, 115WE, 115WF, 115WG, 115WH, WJ, 115WK,] [139,] 143, 144, 147, 148, 154, section (1A) of section 201, sections 210, 211, 234A, 234B, 234C [234E], [270A,] 271 [271C, 271CA] and 273 or otherwise), general or special orders in respect of [any class of incomes or fringe benefits] or class of cases, setting forth directions or instructions (not being prejudicial to assessees) as to the guidelines, principles or procedures to be followed by other income- tax authorities in the work relating to assessment or enue or the initiation of proceedings for the imposition of penalties and any such order may, if the Board is of opinion that it is necessary in the public interest so to do, be published and circulated in the prescribed manner for general information; the Board may, if it considers it desirable or expedient so to do for avoiding genuine hardship in any case or class of cases, by general or special order, authorise [any tax authority, not being a Commissioner (Appeals)] to admit an application or claim for any exemption, deduction, refund or any other relief under this Act after the expiry of the period specified by or under this Act for making such application or claim and deal with the same on merits in accordance with law; revenue, issue, from time to time (whether by way of relaxation of any of the provisions of sections 3[115P, 115S, 115WD, 115WE, 115WF, 115WG, 115WH, WJ, 115WK,] [139,] 143, 144, 147, 148, 154, section (1A) of section 201, sections 210, 211, 234A, 234B, 234C [234E], [270A,] 271 [271C, 271CA] and 273 or otherwise), general or special orders benefits] or class of cases, setting forth directions or instructions (not being prejudicial to assessees) as to the guidelines, - tax authorities in the work relating to assessment or enue or the initiation of proceedings for the imposition of penalties and any such order may, if the Board is of opinion that it is necessary in the public interest so to do, be published and circulated in the the Board may, if it considers it desirable or expedient so to do for avoiding genuine hardship in any case or class of cases, by general or special order, authorise [any tax authority, not being a Commissioner claim for any exemption, deduction, refund or any other relief under this Act after the expiry of the period specified by or under this Act for making such application or claim and deal RAJESH KUMAR 2024.08.01 09:22 I attest to the accuracy and authenticity of this order/judgment. Punjab & Haryana High Court, Chandigarh. CWP-21509-2023 Provided that the Central Government shall cause every order issued under this clause to be laid before each House of Parliament.” 12. Section 120 of the Act, 1961, lays down the jurisdiction of income tax authorities and provides as under: “xx xx xx xx (5) The directions and orders referred to in sub (2) may, wherever considered necessary or appropriate for the proper management of the work, require two or more Assessing Officers (whether or not of the same class) to exercise and perform any area or persons or classes of persons or incomes or classes of income or cases or classes of cases; and, where such powers Page 42 of 46 2023 (O&M) and connected cases. [(c) the Board may, if it considers it desirable or expedient so to do for avoiding genuine hardship in any case or class of cases, by general or special order for reasons to be specified therein, relax any requirement contained in any of the provisions of Chapter IV or Chapte the assessee has failed to comply with any requirement specified in such provision for claiming deduction thereunder, subject to the following conditions, namely. (i) the default in complying with such requirement was due to circumstances bey assessee; and (ii) the assessee has complied with such requirement before the completion of assessment in relation to the previous year in which such deduction is claimed: Provided that the Central Government shall cause every order issued under this clause to be laid before each House of Parliament.” Section 120 of the Act, 1961, lays down the jurisdiction of income tax authorities and provides as under:- “xx xx xx xx (5) The directions and orders referred to in sub (2) may, wherever considered necessary or appropriate for the proper management of the work, require two or more Assessing Officers (whether or not of the same class) to exercise and perform, concurrently, the powers and functions in respect of any area or persons or classes of persons or incomes or classes of income or cases or classes of cases; and, where such powers 46 and connected cases. f it considers it desirable or expedient so to do for avoiding genuine hardship in any case or class of cases, by general or special order for reasons to be specified therein, relax any requirement contained in any of the provisions of Chapter IV or Chapter VI-A, where the assessee has failed to comply with any requirement specified in such provision for claiming deduction thereunder, subject to the following conditions, namely. (i) the default in complying with such requirement was due to circumstances beyond the control of the (ii) the assessee has complied with such requirement before the completion of assessment in relation to the previous year in which such deduction is claimed: Provided that the Central Government shall cause every order issued under this clause to be laid before each House of Section 120 of the Act, 1961, lays down the jurisdiction of - (5) The directions and orders referred to in sub-sections (1) and (2) may, wherever considered necessary or appropriate for the proper management of the work, require two or more Assessing Officers (whether or not of the same class) to exercise and , concurrently, the powers and functions in respect of any area or persons or classes of persons or incomes or classes of income or cases or classes of cases; and, where such powers f it considers it desirable or expedient so to do for avoiding genuine hardship in any case or class of cases, by general or special order for reasons to be specified therein, relax any requirement contained in any A, where the assessee has failed to comply with any requirement specified in such provision for claiming deduction (i) the default in complying with such requirement ond the control of the (ii) the assessee has complied with such requirement before the completion of assessment in relation to the previous year in which such Provided that the Central Government shall cause every order issued under this clause to be laid before each House of Section 120 of the Act, 1961, lays down the jurisdiction of sections (1) and (2) may, wherever considered necessary or appropriate for the proper management of the work, require two or more Assessing Officers (whether or not of the same class) to exercise and , concurrently, the powers and functions in respect of any area or persons or classes of persons or incomes or classes of income or cases or classes of cases; and, where such powers RAJESH KUMAR 2024.08.01 09:22 I attest to the accuracy and authenticity of this order/judgment. Punjab & Haryana High Court, Chandigarh. CWP-21509-2023 and functions are exercised and performed concurrently by the Assessing Of rank amongst them shall exercise the powers and perform the functions as any higher authority amongst them may direct, and, further, references in any other provision of this Act or in any rule made there to be references to such higher authority and any provision of this Act requiring approval or sanction of any such authority shall not apply. (6) Notwithstanding anything contained in any direction or order issued under this section, or in section 124, the Board may, by notification in the Official Gazette, direct that for the purpose of furnishing of the return of income or the doing of any other act or thing under this Act or any rule made thereunder by any person or class of persons, the income and performing the powers and functions in relation to the said person or class of persons shall be such authority as may be specified in the notification.” 13. Section 144B of the Act, 1961 has substituted sub while the faceless assessment provision inserted w.e.f. 01.04.2021 did refer to the returns which may have been submitted on notice under Section 1 the Act, 1961, by the Assessing Officer. The amended provisions of Section 148B now does not refer to notice under Section 148 of the Act, 1961 and only deals with the manner in which the assessment by the National Faceless Assessment Centre is to be 14. It is apposite to quote Section 144B (7) of the Act, 1961, which reads as under: (7)(a) The Principal Chief Commissioner or the Principal Director General, as the case may be, incharge of the National Page 43 of 46 2023 (O&M) and connected cases. and functions are exercised and performed concurrently by the Assessing Officers of different classes, any authority lower in rank amongst them shall exercise the powers and perform the functions as any higher authority amongst them may direct, and, further, references in any other provision of this Act or in any rule made thereunder to the Assessing Officer shall be deemed to be references to such higher authority and any provision of this Act requiring approval or sanction of any such authority shall not apply. (6) Notwithstanding anything contained in any direction or order ssued under this section, or in section 124, the Board may, by notification in the Official Gazette, direct that for the purpose of furnishing of the return of income or the doing of any other act or thing under this Act or any rule made thereunder by any person or class of persons, the income and performing the powers and functions in relation to the said person or class of persons shall be such authority as may be specified in the notification.” Section 144B of the Act, 1961, as substituted w.e.f. 01.04.2022, has substituted sub-section 128 which has been inserted w.e.f 01.04.2022 while the faceless assessment provision inserted w.e.f. 01.04.2021 did refer to the returns which may have been submitted on notice under Section 1 the Act, 1961, by the Assessing Officer. The amended provisions of Section 148B now does not refer to notice under Section 148 of the Act, 1961 and only deals with the manner in which the assessment by the National Faceless Assessment Centre is to be done. It is apposite to quote Section 144B (7) of the Act, 1961, which reads as under:- (7)(a) The Principal Chief Commissioner or the Principal Director General, as the case may be, incharge of the National 46 and connected cases. and functions are exercised and performed concurrently by the ficers of different classes, any authority lower in rank amongst them shall exercise the powers and perform the functions as any higher authority amongst them may direct, and, further, references in any other provision of this Act or in any under to the Assessing Officer shall be deemed to be references to such higher authority and any provision of this Act requiring approval or sanction of any such authority (6) Notwithstanding anything contained in any direction or order ssued under this section, or in section 124, the Board may, by notification in the Official Gazette, direct that for the purpose of furnishing of the return of income or the doing of any other act or thing under this Act or any rule made thereunder by any person or class of persons, the income-tax authority exercising and performing the powers and functions in relation to the said person or class of persons shall be such authority as may be , as substituted w.e.f. 01.04.2022, been inserted w.e.f 01.04.2022 while the faceless assessment provision inserted w.e.f. 01.04.2021 did refer to the returns which may have been submitted on notice under Section 148 of the Act, 1961, by the Assessing Officer. The amended provisions of Section 148B now does not refer to notice under Section 148 of the Act, 1961 and only deals with the manner in which the assessment by the National Faceless It is apposite to quote Section 144B (7) of the Act, 1961, which (7)(a) The Principal Chief Commissioner or the Principal Director General, as the case may be, incharge of the National and functions are exercised and performed concurrently by the ficers of different classes, any authority lower in rank amongst them shall exercise the powers and perform the functions as any higher authority amongst them may direct, and, further, references in any other provision of this Act or in any under to the Assessing Officer shall be deemed to be references to such higher authority and any provision of this Act requiring approval or sanction of any such authority (6) Notwithstanding anything contained in any direction or order ssued under this section, or in section 124, the Board may, by notification in the Official Gazette, direct that for the purpose of furnishing of the return of income or the doing of any other act or thing under this Act or any rule made thereunder by any tax authority exercising and performing the powers and functions in relation to the said person or class of persons shall be such authority as may be , as substituted w.e.f. 01.04.2022, been inserted w.e.f 01.04.2022 while the faceless assessment provision inserted w.e.f. 01.04.2021 did refer 48 of the Act, 1961, by the Assessing Officer. The amended provisions of Section 148B now does not refer to notice under Section 148 of the Act, 1961 and only deals with the manner in which the assessment by the National Faceless It is apposite to quote Section 144B (7) of the Act, 1961, which (7)(a) The Principal Chief Commissioner or the Principal Director General, as the case may be, incharge of the National RAJESH KUMAR 2024.08.01 09:22 I attest to the accuracy and authenticity of this order/judgment. Punjab & Haryana High Court, Chandigarh. CWP-21509-2023 Faceless Assessment Centre shall, in acco procedure laid down by the Board in this regard, if he considers appropriate that the provisions of sub 142 may be invoked in the case: (8) Notwithstanding anything contain sub Principal Director General, as the case may be, in National Faceless Assessment Centre may, at any stage of the assessment, if consider Page 44 of 46 2023 (O&M) and connected cases. Faceless Assessment Centre shall, in acco procedure laid down by the Board in this regard, if he considers appropriate that the provisions of sub 142 may be invoked in the case:- (1) forward the reference received from an assessment unit under clause (xxxii) Principal Chief Commissioner or Chief Commissioner or Principal Commissioner or Commissioner having jurisdiction over such case, and inform the assessment unit accordingly; (ii) transfer the case to the Assessing Officer having jurisdiction over such case in accordance with sub (8); (b) where a reference has been received by the Principal Chief Commissioner or Chief Commissioner or Principal Commissioner or Commissioner under sub clause (a), he shall direct t jurisdiction over the case, to invoke the provisions of sub section (2A) of section 142; (c) where a reference has not been forwarded to the Principal Chief Commissioner or Chief Commissioner or Principal Commissioner or Commis jurisdiction over the case, in a case referred to in sub clause (1) of clause (a), the assessment unit shall proceed to complete the assessment in accordance with the procedure laid down in this section. (8) Notwithstanding anything contain sub-section (2), the Principal Chief Commissioner or the Principal Director General, as the case may be, in National Faceless Assessment Centre may, at any stage of the assessment, if considers necessary, transfer the cas 46 and connected cases. Faceless Assessment Centre shall, in accordance with the procedure laid down by the Board in this regard, if he considers appropriate that the provisions of sub-section (2A) of section - (1) forward the reference received from an assessment unit under clause (xxxii) of sub-section (1) to the Principal Chief Commissioner or Chief Commissioner or Principal Commissioner or Commissioner having jurisdiction over such case, and inform the assessment (ii) transfer the case to the Assessing Officer having urisdiction over such case in accordance with sub-section (b) where a reference has been received by the Principal Chief Commissioner or Chief Commissioner or Principal Commissioner under sub-clause (1) of clause (a), he shall direct the Assessing Officer, having jurisdiction over the case, to invoke the provisions of sub- section (2A) of section 142; (c) where a reference has not been forwarded to the Principal Chief Commissioner or Chief Commissioner or Principal Commissioner or Commissioner, having jurisdiction over the case, in a case referred to in sub- clause (1) of clause (a), the assessment unit shall proceed to complete the assessment in accordance with the procedure laid down in this section. (8) Notwithstanding anything contained in sub-section (1) or section (2), the Principal Chief Commissioner or the Principal Director General, as the case may be, in-charge of National Faceless Assessment Centre may, at any stage of the necessary, transfer the case to the rdance with the procedure laid down by the Board in this regard, if he considers section (2A) of section (1) forward the reference received from an assessment section (1) to the Principal Chief Commissioner or Chief Commissioner or Principal Commissioner or Commissioner having jurisdiction over such case, and inform the assessment (ii) transfer the case to the Assessing Officer having section (b) where a reference has been received by the Principal Chief Commissioner or Chief Commissioner or Principal clause (1) of he Assessing Officer, having - (c) where a reference has not been forwarded to the Principal Chief Commissioner or Chief Commissioner or sioner, having - clause (1) of clause (a), the assessment unit shall proceed to complete the assessment in accordance with the section (1) or section (2), the Principal Chief Commissioner or the charge of National Faceless Assessment Centre may, at any stage of the e to the RAJESH KUMAR 2024.08.01 09:22 I attest to the accuracy and authenticity of this order/judgment. Punjab & Haryana High Court, Chandigarh. CWP-21509-2023 Assessing Officer having jurisdiction over such case, with the prior approval of the Board.” 15. Thus it is in the aforesaid two contingencies alone as provided under sub-Sections 7 and 8 that the Principal Chief Commissioner or the Principal Director General, as the case may be, transfer the case to the Assessing Officer having jurisdiction over such power of transfer to the JAO is although available but it has to be exercised only in a particular case considering the facts and circumstances therein and not by way of general order as passed vide letter dated 19.01.2024. 16. We are in agreement with the view taken by the Coordinate Bench and hold that such circular or instructions by the Board could not have been issued to override statutory provisions or to make them otiose or obsolete. Legislative enactments having financial be followed strictly and mandatorily. By exercising the powers contained Sections 119 and 120 of the Act, 1961 as well as Section 144B (7 & 8), the authorities cannot be allowed to usurp the legal provisions to their own satisfaction and convenience causing hardship to the assessees. It also leaves confusion in the minds of the taxpayers instructions and supplementing the statutory provisions and 17. In view of the aforesaid discussion, there is no occasion to distinguish or take a different view as suggested by the learned counsel for the revenue from what has already been held by the Coordinate Bench. 18. Keeping in view the law laid down by the Coordinate Bench (supra), notices issued by the JAO under Section 148 of the Act, 1961 and the Page 45 of 46 2023 (O&M) and connected cases. Assessing Officer having jurisdiction over such case, with the prior approval of the Board.” Thus it is in the aforesaid two contingencies alone as provided Sections 7 and 8 that the Principal Chief Commissioner or the Principal Director General, as the case may be, transfer the case to the Assessing Officer having jurisdiction over such power of transfer to the JAO is although available but it has to be exercised only in a particular case considering the facts and circumstances therein and not by way of general order as passed vide letter dated 19.01.2024. We are in agreement with the view taken by the Coordinate Bench and hold that such circular or instructions by the Board could not have been issued to override statutory provisions or to make them otiose or obsolete. Legislative enactments having financial be followed strictly and mandatorily. By exercising the powers contained Sections 119 and 120 of the Act, 1961 as well as Section 144B (7 & 8), the authorities cannot be allowed to usurp the legal provisions to their own tisfaction and convenience causing hardship to the assessees. It also leaves n in the minds of the taxpayers. instructions and circulars can be issued only for the purpose of supplementing the statutory provisions and for In view of the aforesaid discussion, there is no occasion to distinguish or take a different view as suggested by the learned counsel for the revenue from what has already been held by the Coordinate Bench. Keeping in view the law laid down by the Coordinate Bench (supra), notices issued by the JAO under Section 148 of the Act, 1961 and the 46 and connected cases. Assessing Officer having jurisdiction over such case, with the Thus it is in the aforesaid two contingencies alone as provided Sections 7 and 8 that the Principal Chief Commissioner or the Principal Director General, as the case may be, transfer the case to the Assessing Officer having jurisdiction over such case i.e. JAO. Thus, the power of transfer to the JAO is although available but it has to be exercised only in a particular case considering the facts and circumstances therein and not by way of general order as passed vide letter dated 19.01.2024. We are in agreement with the view taken by the Coordinate Bench and hold that such circular or instructions by the Board could not have been issued to override statutory provisions or to make them otiose or obsolete. Legislative enactments having financial implications are required to be followed strictly and mandatorily. By exercising the powers contained in Sections 119 and 120 of the Act, 1961 as well as Section 144B (7 & 8), the authorities cannot be allowed to usurp the legal provisions to their own tisfaction and convenience causing hardship to the assessees. It also leaves In the opinion of this Court, can be issued only for the purpose of for their implementation. In view of the aforesaid discussion, there is no occasion to distinguish or take a different view as suggested by the learned counsel for the revenue from what has already been held by the Coordinate Bench. Keeping in view the law laid down by the Coordinate Bench (supra), notices issued by the JAO under Section 148 of the Act, 1961 and the Assessing Officer having jurisdiction over such case, with the Thus it is in the aforesaid two contingencies alone as provided Sections 7 and 8 that the Principal Chief Commissioner or the Principal Director General, as the case may be, transfer the case to the case i.e. JAO. Thus, the power of transfer to the JAO is although available but it has to be exercised only in a particular case considering the facts and circumstances therein and We are in agreement with the view taken by the Coordinate Bench and hold that such circular or instructions by the Board could not have been issued to override statutory provisions or to make them otiose or implications are required to in Sections 119 and 120 of the Act, 1961 as well as Section 144B (7 & 8), the authorities cannot be allowed to usurp the legal provisions to their own tisfaction and convenience causing hardship to the assessees. It also leaves In the opinion of this Court, can be issued only for the purpose of In view of the aforesaid discussion, there is no occasion to distinguish or take a different view as suggested by the learned counsel for Keeping in view the law laid down by the Coordinate Bench (supra), notices issued by the JAO under Section 148 of the Act, 1961 and the RAJESH KUMAR 2024.08.01 09:22 I attest to the accuracy and authenticity of this order/judgment. Punjab & Haryana High Court, Chandigarh. CWP-21509-2023 proceedings initiated thereafter without conducting the faceless assessment as envisaged under Section 144B of the Act, contrary to the provisions of the Act, 1961 and accordingly 28.02.2023, 16.03.2023, 20.03.2024 and 30.03.2023 and order dated 30.03.2023, are 19. The respondents the procedure as laid down under the Act, 1961 and proceed accordingly, if so advised. 20. All the writ petition the Court shall stand merged with the present order. 21. No 22. All pending misc. application(s) also stand disposed of. 29.07.2024. rajesh 1. Whether speaking/reasoned? 2. Whether reportable? Page 46 of 46 2023 (O&M) and connected cases. proceedings initiated thereafter without conducting the faceless assessment as envisaged under Section 144B of the Act, contrary to the provisions of the Act, 1961 and accordingly 28.02.2023, 16.03.2023, 20.03.2024 and 30.03.2023 and order dated 30.03.2023, are set aside for want of jurisdiction. The respondents-revenue would the procedure as laid down under the Act, 1961 and proceed accordingly, if All the writ petitions are allowed. The interim order passed by the Court shall stand merged with the present order. No costs. All pending misc. application(s) also stand disposed of. (SANJEEV PRAKASH SHARMA) (SANJAY VASHISTH 1. Whether speaking/reasoned? : 2. Whether reportable? : 46 and connected cases. proceedings initiated thereafter without conducting the faceless assessment as envisaged under Section 144B of the Act, 1961, have been found to be contrary to the provisions of the Act, 1961 and accordingly notices dated 28.02.2023, 16.03.2023, 20.03.2024 and 30.03.2023 and order dated set aside for want of jurisdiction. be, however, at liberty to follow the procedure as laid down under the Act, 1961 and proceed accordingly, if are allowed. The interim order passed by the Court shall stand merged with the present order. All pending misc. application(s) also stand disposed of. (SANJEEV PRAKASH SHARMA) JUDGE (SANJAY VASHISTH) JUDGE : Yes/No : Yes/No proceedings initiated thereafter without conducting the faceless assessment as 1961, have been found to be notices dated 28.02.2023, 16.03.2023, 20.03.2024 and 30.03.2023 and order dated be, however, at liberty to follow the procedure as laid down under the Act, 1961 and proceed accordingly, if are allowed. The interim order passed by RAJESH KUMAR 2024.08.01 09:22 I attest to the accuracy and authenticity of this order/judgment. Punjab & Haryana High Court, Chandigarh. "
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