IN THE HIGHH COURT OF PUNJAB & HARYAANA AT CHANDIGARH Sr. No.130 CWP-21447-2025 Date of decision : 29.07.2025 Moonlight Properties Pvt. Ltd. .…. Petitioner Versus Assistant Commissiioner of Income Tax, Chandigarh and othhers ..... Respondents CORAM : HON 'BLE MR. JUSTICE DEEPAK SIBBAL HON 'BLE MS. JUSTICE LAPITA BANNERJI Present : Mr. KKartik Bansal, Advocate, for the pettitioner. Mr. YYogesh Putney, Senior Standing Coounsel, with Mr. VVaibhav Gupta, Junior Standing Co unsel, for thhe Income Tax Department. * * * * * DEEPAK SIBAL, JJ. (Oral) 1. Challenge made through the instant petition is to the notice dated 22.03.2024 (Annexxure P-1) issued to the petitioner bby the respondents under Section 148 of the Income Tax Act, 1961. The primary grround of challenge raised by the petitioner is that thhe impugned notice has been issuedd by the Jurisdictional Assessing Officer which coulld have not been done because inn terms of the notification dated 29.03.2022 (Annexxure P-2) issued by the Ministry oof Finance, Government of India, the impugned notic e could have been issued only by wway of faceless assessment. 2. In suppport of his afore submission, leearned counsel for the petitioner places reliance on thhe following two judgments of thiss Court:- (i) CWWP-15745-2024, titled Jatinder Sinngh Bhangu vs. Union of Inddia and others, decided on 19.07.20024; and (ii) CWWP-21509-2023, titled Jasjit Singhh vs. Union of India and oothers, decided on 29.07.2024.

3. Learnned counsel for the respondents ddoes not dispute the fact that the case of the petitiooner is covered in its favour by the law laid down through the SHAMSHER SINGH 2025.08.07 10:34 I attest to the accuracy and integrity of this document Punjab and haryana high court, chandigarh CWP-21447-2025 [ 2 ] aforesaid two judgmments rendered by two different c o-ordinate Benches of this Court in the cases of Jatinnder Singh Bhangu and Jasjit Singhh (supra). 4. In thee light of the above, in terms of thhe law laid down in the cases of Jatinder Singh Bhangu and Jasjit Singh (supra), the immpugned notice dated 22.03.2024 (Annexure P-1) issuued by the Jurisdictional Assessingg Officer, is hereby quashed with liberty to the responndents to proceed against the petitiooner in accordance with law. 5. The ppetition is allowed in the above termms. [DEEPAK SIBAL] JUDGE 29.07.2025 [LAPITA BANERJI] shamsher JUDGE Whether speaking/reasoned : Yes / Noo Whether reportable : Yes / Noo SHAMSHER SINGH 2025.08.07 10:34 I attest to the accuracy and integrity of this document Punjab and haryana high court, chandigarh

IN THE HIGHH COURT OF PUNJAB & HARYAANA AT CHANDIGARH Sr. No.130 CWP-21447-2025 Date of decision : 29.07.2025 Moonlight Properties Pvt. Ltd. .…. Petitioner Versus Assistant Commissiioner of Income Tax, Chandigarh and othhers ..... Respondents CORAM : HON 'BLE MR. JUSTICE DEEPAK SIBBAL HON 'BLE MS. JUSTICE LAPITA BANNERJI Present : Mr. KKartik Bansal, Advocate, for the pettitioner. Mr. YYogesh Putney, Senior Standing Coounsel, with Mr. VVaibhav Gupta, Junior Standing Co unsel, for thhe Income Tax Department. * * * * * DEEPAK SIBAL, JJ. (Oral) 1. Challenge made through the instant petition is to the notice dated 22.03.2024 (Annexxure P-1) issued to the petitioner bby the respondents under Section 148 of the Income Tax Act, 1961. The primary grround of challenge raised by the petitioner is that thhe impugned notice has been issuedd by the Jurisdictional Assessing Officer which coulld have not been done because inn terms of the notification dated 29.03.2022 (Annexxure P-2) issued by the Ministry oof Finance, Government of India, the impugned notic e could have been issued only by wway of faceless assessment. 2. In suppport of his afore submission, leearned counsel for the petitioner places reliance on thhe following two judgments of thiss Court:- (i) CWWP-15745-2024, titled Jatinder Sinngh Bhangu vs. Union of Inddia and others, decided on 19.07.20024; and (ii) CWWP-21509-2023, titled Jasjit Singhh vs. Union of India and oothers, decided on 29.07.2024.

3. Learnned counsel for the respondents ddoes not dispute the fact that the case of the petitiooner is covered in its favour by the law laid down through the SHAMSHER SINGH 2025.08.07 10:34 I attest to the accuracy and integrity of this document Punjab and haryana high court, chandigarh CWP-21447-2025 [ 2 ] aforesaid two judgmments rendered by two different c o-ordinate Benches of this Court in the cases of Jatinnder Singh Bhangu and Jasjit Singhh (supra). 4. In thee light of the above, in terms of thhe law laid down in the cases of Jatinder Singh Bhangu and Jasjit Singh (supra), the immpugned notice dated 22.03.2024 (Annexure P-1) issuued by the Jurisdictional Assessingg Officer, is hereby quashed with liberty to the responndents to proceed against the petitiooner in accordance with law. 5. The ppetition is allowed in the above termms. [DEEPAK SIBAL] JUDGE 29.07.2025 [LAPITA BANERJI] shamsher JUDGE Whether speaking/reasoned : Yes / Noo Whether reportable : Yes / Noo SHAMSHER SINGH 2025.08.07 10:34 I attest to the accuracy and integrity of this document Punjab and haryana high court, chandigarh