2025 (7) TMI 2015

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....or the Petitioner: Mr. B.M. Monga, Advocate,. For the Respondent(s)-Income Tax Department: Mr. Saurabh Kapoor, Advocate,. LISA GILL, J. 1. Challenge in the present petition is to impugned notice dated 19.04.2024 issued under Section 148 of the Income Tax Act, 1961 (for short "Act 1961"), order dated 19.04.2024 under Section 148A(d) of Act 1961 and all consequential proceedings for the Ass....

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....ndents has also not disputed the same. 4. We have heard learned counsel for the parties and perused the file with their able assistance. 5. Co-ordinate Bench of this Court in Jatinder Singh Bhangu's case (supra) and Jasjit Singh's case (supra), allowed the writ petitions on the same issue, as raised in the present writ petition, by granting liberty to the revenue to follow the proced....

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....ng Officer. The respondents are heavily placing reliance upon office memorandum and letter issued by departmental authorities. It is axiomatic in tax jurisprudence that circulars, instructions and letters issued by Board or any other authority cannot override statutory provisions. The circulars are binding upon authorities and Courts are not bound by circulars. The mandate of Section 144B, 151A re....