High Court of Punjab and Haryana · Judgments and reasoned final orders
Ruchi Jain v. Income Tax Officer, Ward-1, Panipat & Ors. (CWP-18774-2026)
Civil Writ Petition No. 18774 of 2026 ·
Quashing of Section 148A(d) order dated 28.07.2022, consequential reassessment order dated 19.01.2026, demand notice, and Section 271(1)(c) penalty order in terms of Suman Kandoi v. NFAC [2026] 182 taxmann.com 789 (P&H).
1. FACTS OF THE CASE
The petitioner filed CWP-18774-2026 seeking quashing of the order dated 28.07.2022 passed under Section 148A(d), the consequential reassessment order dated 19.01.2026, the demand notice dated 19.01.2026, and the penalty order dated 08.06.2026 passed under Section 271(1)(c).
2. DISCUSSION BY THE COURT
Counsel for the petitioner submitted, and counsel for the Revenue was unable to dispute, that the controversy is squarely covered in favour of the assessee by the coordinate bench decision of the Punjab and Haryana High Court in Suman Kandoi v. National Faceless Assessment Centre, Delhi & Ors., [2026] 182 taxmann.com 789 (P&H).
3. JUDICIAL DECISION
Allowing the writ petition in the same terms as Suman Kandoi v. NFAC [2026] 182 taxmann.com 789 (P&H), the High Court set aside the order dated 28.07.2022 under Section 148A(d), the reassessment order dated 19.01.2026, the demand notice dated 19.01.2026, and the penalty order dated 08.06.2026 under Section 271(1)(c).
4. OUTCOME
Assessee - Writ petition allowed; reassessment order, demand notice, and Section 271(1)(c) penalty order set aside.
5. AKHB REVIEW POINT
Where the foundational Section 148A(d) order and Section 148 notice are vitiated under Suman Kandoi v. NFAC [2026] 182 taxmann.com 789 (P&H), the subsequent reassessment order and Section 271(1)(c) penalty order collapse automatically.
Source and verification
2-page official High Court of Punjab and Haryana judgment PDF (20260701_PHHC010978682026.pdf, 117,707 bytes).
Original PDF: 2 pages · SHA-256: bc92bfcadfe325ce600cb42623547e84536d57cc433f7f66a4eddbfc25824935
Supplied source-reviewed note retained; original bytes and identity validation checked in this release. Substantive re-review is not claimed for this record.
Applies Sections 147, 148, 148A(d), 156, and 271(1)(c) of the Income-tax Act, 1961. Income-tax Act, 2025 equivalence is not verified.
Full 2-page primary judgment PDF text read and verified page-by-page. Follows coordinate bench decision in Suman Kandoi v. NFAC, Delhi & Ors. [2026] 182 taxmann.com 789 (P&H).
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General research only. Read the complete judgment and verify applicable law and subsequent treatment before reliance.