Mangat Raj V. Union of India and others

CWP/13746/2025

AI Insights

The case revolves around a challenge to notices issued under Section 148 and Section 156 of the Income Tax Act, 1961, for the assessment year 2020-2021. The petitioner, Mangat Raj, contested the validity of these notices on the grounds that they were issued by a jurisdictional assessing officer contrary to the faceless assessment procedure required by a notification from the Ministry of Finance dated 29.03.2022. The Income Tax Department, represented by Mr. Yogesh Putney and Mr. Vaibhav Gupta, did not dispute the applicability of the precedents cited by the petitioner. The court's decision was influenced by earlier judgments which had established the necessity of adhering to the faceless assessment procedure in similar circumstances.

• Counselvise Citation: [2025] 140 COUNSELVISE.COM (IT) 800349 (HC-MISC)
• Appeal Type: Others
• Pronouncement Date: 14-05-2025
• Assessment Year: misc
• Other Referred Cases: Jatinder Singh Bhangu Vs. Union of India and others, Jasjit Singh Vs. Union of India and others
• Laws Referred To: Income Tax Act, 1961
• Result in Favour of: Others
• Court: HIGH COURT
• Department Lawyers: YOGESH PUTNEY; VAIBHAV GUPTA
• Assessee Lawyers: SANDEEP GOYAL
• Keywords: Faceless assessment; Jurisdictional Assessing Officer; Notice Challenge
• Section: 148; 156

Judgement Text

"CWP-13746-2025 IN THE HIGH COURT OF PUNJAB AND HARYANA AT Mangat Raj Union of India and others CORAM : HON’BLE MR. JUSTICE HON’BLE MS. JUSTICE LAPITA Present : Mr. for the petitioner. Mr. Yogesh Putney, Sr. Standing Counsel and Mr. Vaibhav Gupta, Jr. for the Income Tax Department. DEEPAK SIBAL Challenge in the prese issued under Section 148 of the Income Tax Act, 1961 (for short ‘1961 assessment order dated 13.03.2025 and issued under Section 156 of the 2. The primary ground of challenge raised by the petitioner is that the impugned notice has been issued by the Jurisdictio which could have not been done because in terms of the notificatio 29.03.2022 (Annexure P of India, the impugned notice could have been issued only by way of faceless assessment. 3. In support of his afore submission, learned counsel for the petitioner places reliance on the following two judgments of this Court: i) CWP of India and others 2025 (O&M) Sr. No.169 IN THE HIGH COURT OF PUNJAB AND HARYANA AT CHANDIGARH CWP-13746 Date of Decision : …Petitioner Versus Union of India and others …Respondent HON’BLE MR. JUSTICE DEEPAK SIBAL HON’BLE MS. JUSTICE LAPITA Mr. Sandeep Goyal, Advocate, for the petitioner. Mr. Yogesh Putney, Sr. Standing Counsel and Mr. Vaibhav Gupta, Jr. Standing Counsel, for the Income Tax Department. *** DEEPAK SIBAL, J. (ORAL) Challenge in the present petition is to notice dated issued under Section 148 of the Income Tax Act, 1961 (for short ‘1961 assessment order dated 13.03.2025 and notice of demand dated er Section 156 of the 1961 Act, for AY 2020 The primary ground of challenge raised by the petitioner is that the impugned notice has been issued by the Jurisdictio which could have not been done because in terms of the notificatio 29.03.2022 (Annexure P-12), issued by the Ministry of Finance, Government of India, the impugned notice could have been issued only by way of faceless In support of his afore submission, learned counsel for the petitioner places reliance on the following two judgments of this Court: i) CWP-15745-2024, titled Jatinder Singh Bhangu of India and others, decided on 19.07.2024; and Page 1 of 2 IN THE HIGH COURT OF PUNJAB AND HARYANA AT CHANDIGARH 13746-2025 (O&M) Date of Decision : 14.05.2025 …Petitioner …Respondents DEEPAK SIBAL HON’BLE MS. JUSTICE LAPITA BANERJI Mr. Yogesh Putney, Sr. Standing Counsel and Standing Counsel, nt petition is to notice dated 21.02.2024 issued under Section 148 of the Income Tax Act, 1961 (for short ‘1961 Act’); notice of demand dated 13.03.2025 for AY 2020-2021. The primary ground of challenge raised by the petitioner is that the impugned notice has been issued by the Jurisdictional Assessing Officer which could have not been done because in terms of the notification dated ), issued by the Ministry of Finance, Government of India, the impugned notice could have been issued only by way of faceless In support of his afore submission, learned counsel for the petitioner places reliance on the following two judgments of this Court:- Jatinder Singh Bhangu Vs. Union , decided on 19.07.2024; and VANDANA 2025.05.20 09:51 I attest to the accuracy and integrity of this document CWP-13746-2025 ii) CWP others 4. Learned counsel for the respondents does not dispute the fact that the case of the petitioner is covered in its favour by the law laid down through the aforesaid two judgments rendered by two different co this Court in Jatinder Singh Bh 5. In the light of the above, the of Jatinder Singh Bhangu’s 19.07.2024 and 29.07.2024, respectively. 8. All the pending May 14, 2025 vandana Whether speaking/reasoned : Whether reportable : 2025 (O&M) ii) CWP-21509-2023, titled Jasjit Singh others, decided on 29.07.2024. Learned counsel for the respondents does not dispute the fact that the case of the petitioner is covered in its favour by the law laid down through the aforesaid two judgments rendered by two different co Jatinder Singh Bhangu’s and Jasjit Singh’s In the light of the above, the present Jatinder Singh Bhangu’s and Jasjit Singh’s 19.07.2024 and 29.07.2024, respectively. All the pending applications, if any, also stand disposed of. (DEEPAK SIBAL JUDGE (LAPITA BANERJI) JUDGE 5 Whether speaking/reasoned : Yes/No Whether reportable : Yes/No Page 2 of 2 Jasjit Singh Vs. Union of India and Learned counsel for the respondents does not dispute the fact that the case of the petitioner is covered in its favour by the law laid down through the aforesaid two judgments rendered by two different co-ordinate Benches of Jasjit Singh’s case (supra). present petition is allowed in terms Jasjit Singh’s cases (supra), decided on applications, if any, also stand disposed of. DEEPAK SIBAL) JUDGE (LAPITA BANERJI) JUDGE VANDANA 2025.05.20 09:51 I attest to the accuracy and integrity of this document "