2025 (5) TMI 2212

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....aj Bhalla, CA. For the Revenue : Shri Manav Bansal, CIT DR. ORDER PER RAJ PAL YADAV, VP The Revenue is in appeal before the Tribunal against the order of ld. CIT(A) dated 19.07.2024 passed for assessment year 2019-20. 2. On receipt of notice in the Revenue's appeal, assessee has filed Cross Objection bearing No. 41/CHD/2024. 3. In the Cross Objection, assessee has taken Ground No....

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....g and not by the jurisdictional AO. He submitted that a similar notice was issued by the AO in the subsequent year which was challenged by the assessee by way of a Writ Petition bearing No. 11870 of 2025. This Writ Petition has been decided by the Hon'ble jurisdictional High Court wherein Hon'ble jurisdictional High Court has followed its judgement in the case of Jatinder Singh Bhangu Vs U....

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....on 29.03.2022. The notice under Section 148 has been issued on 29.03.2023 i.e. almost one year from the Notification. Thus, facts of other year are squarely applicable. The issue in dispute is covered by the judgement of Hon'ble jurisdictional High Court which read as under : "DEEPAK SIBAL, J. (Oral) 1. Challenge made through the instant petition is to the notice dated 01.03.....

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....s. Union of India and others, decided on 29.07.2024. 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's case (supra).. 4. In the light of the above, i....