Punjab and Haryana High Court
CWP/19704/2025 of PATNA SAHIB CHARITABLE EDUCATIONAL TRUST Vs INCOME TAX OFFICER EXEMPTIONS WARD, CHANDIGARH AND OTHERS on 10 September 2026
COURT OF PUNJAB AND HARYANA AT CHANDIGARH Sr. No.128 CWP-19704-2025 Date of decision: 16.07.2025 Patna Sahib Charitable Education Trust ....Petitioner Versus Income Tax Officer Exemptions Ward, Chandigarh and others ....Respondents CORAM: HON'BLE MR. JUSTICE DEEPAK SIBAL HON'BLE MS. JUSTICE
IN THE HIGH COURT OF PUNJAB AND HARYANA
AT CHANDIGARH
Sr. No.128
CWP-19704-2025
Date of decision: 16.07.2025
Patna Sahib Charitable Education Trust
....Petitioner
Versus
Income Tax Officer Exemptions Ward, Chandigarh and others
....Respondents
CORAM:
HON'BLE MR. JUSTICE DEEPAK SIBAL
HON'BLE MS. JUSTICE LAPITA BANERJI
Present:
Mr. Kartik Bansal, Advocate, for the petitioner.
Mr. Yogesh Putney, Sr. Standing Counsel
Mr. Vaibhav Gupta, Jr. Standing Counsel and Mr. Vidul Kapoor, Jr. Standing Counsel, for the respondents.
* * *
DEEPAK SIBAL, J. (Oral)
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1. Challenge made through the instant petition is to the notice dated 16.04.2024 (Annexure P-1) issued to the petitioner by the respondents under Section 148 of the Income Tax Act, 1961. The primary ground of challenge raised by the petitioner is that the impugned notice has been issued by the Jurisdictional Assessing Officer which could have not been done because in terms of the notification dated 29.03.2022 (Annexure P-2), issued by the Ministry of Finance, Government of India, the impugned notice could have been issued only by way of faceless assessment.
2. 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 vs. Union of India and others, decided on 19.07.2024; and
(ii) CWP-21509-2023, titled Jasjit Singh vs. Union of India and others, decided on 29.07.2024.
JYOTI SHARMA 2025.07.18 09:34 I attest to the accuracy and integrity of this document chandigarh
CWP-19704-2025 -2-
3. Learned counsel for the respondents 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 and Jasjit Singh (supra).
4. In the light of the above, in terms of the law laid down in the cases of Jatinder Singh Bhangu and Jasjit Singh (supra), the impugned notice dated 16.04.2024 (Annexure P-1), issued by the Jurisdictional Assessing Officer, is hereby quashed with liberty to the respondents to proceed against the petitioner in accordance with law.
5. The petition is allowed in the above terms. (DEEPAK SIBAL) JUDGE (LAPITA BANERJI) JUDGE July 16, 2025 Jyoti 1 Whether speaking/reasoned Yes/No Whether reportable Yes/No JYOTI SHARMA 2025.07.18 09:34 I attest to the accuracy and integrity of this document chandigarh