SHL Agro Food Inc. V. National Faceless Assessment Centre, New Delhi and another

CWP/37971/2025

AI Insights

The case involves SHL Agro Food Inc., the petitioner, challenging a notice issued by the National Faceless Assessment Centre, New Delhi, and another respondent, under Section 148 of the Income Tax Act, 1961. The notice was contested on the grounds that it was issued by the Jurisdictional Assessing Officer, contrary to the requirements of a faceless assessment as per the Ministry of Finance's notification dated 29.03.2022. The petitioner relied on precedents set by two previous judgments of the High Court, which supported the argument for faceless assessment. The court, acknowledging the precedents and the submissions, quashed the notice and allowed the respondents to reissue it in compliance with the faceless assessment procedure.

• Counselvise Citation: [2025] 140 COUNSELVISE.COM (IT) 824214 (HC-CHANDIGARH)
• Appeal Type: Others
• Pronouncement Date: 19-12-2025
• 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: URVASHI DHUGGA; VIDUL KAPOOR; KAVITA
• Assessee Lawyers: DEEPAK AGGARWAL
• Keywords: Faceless assessment; Jurisdictional Assessing Officer; Notice Challenge
• Section: 148

Judgement Text

" IN THE HIGH COURT OF PUNJAB & HARYANA AT CHANDIGARH ( Sr. No. 121 ) CWP No.37971 of 2025 Date of decision: 19.12.2025 SHL Agro Food Inc. .....Petitioner Versus National Faceless Assessment Centre, New Delhi and another .....Respondents CORAM : HON'BLE MR. JUSTICE DEEPAK SIBAL HON'BLE MS. JUSTICE LAPITA BANERJI Present : Mr. Deepak Aggarwal, Advocate for the petitioner. Ms. Urvashi Dhugga, Senior Standing Counsel with Mr. Vidul Kapoor, Junior Standing Counsel and Ms. Kavita, Advocate for the respondent(s)- Income Tax Department. * * * DEEPAK SIBAL, J. (Oral) (1) Challenge made through the instant petition is to the notice dated 05.04.2024 (Annexure P-1) issued to the petitioner by the respondent under Section 148 of the Income Tax Act, 1961 and all consequential proceedings for the Assessment year 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 not have been done because in terms of the notification dated 29.03.2022, issued by the Ministry of Finance, Government of India, the impugned notice could have been issued only by way of faceless assessment. Printed from counselvise.com SUNIL YADAV 2025.12.19 13:08 I attest to the accuracy and authenticity of this order. Chandigarh CWP No.37971 of 2025 [2] (2) In support of his afore submission, learned counsel for the petitioner places reliance on the following two judgments of this Court :- (i) CWP No.15745 of 2024 - Jatinder Singh Bhangu Vs. Union of India and others, decided on 19.07.2024. (ii) CWP No.21509 of 2023 - Jasjit Singh Vs. Union of India and others, decided on 29.07.2024. (3) Learned counsel for the respondent(s)-Income Tax Department does not dispute the fact that the case of the petitioner is covered in his favour by the law laid down through the aforesaid two judgments rendered by two different Co-ordinate Benches of this Court in Jatinder Singh Bhangu’s and Jasjit Singh’s cases (supra). (4) In the light of the above, in terms of the law laid down in Jatinder Singh Bhangu’s and Jasjit Singh’s cases (supra), the impugned notice dated 05.04.2024 (Annexure P-1) issued by the Jurisdictional Assessing Officer, is hereby quashed with liberty to the respondent to proceed against the petitioner in accordance with law. (5) The petition is allowed in the above terms. (DEEPAK SIBAL) JUDGE 19.12.2025 ( LAPITA BANERJI ) sunil yadav JUDGE Whether speaking/reasoned : Yes / No Whether reportable : Yes / No Printed from counselvise.com SUNIL YADAV 2025.12.19 13:08 I attest to the accuracy and authenticity of this order. Chandigarh "