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2025 Supreme(Online)(P&H) 23387

IN THE HIGH COURT OF PUNJAB AND HARYANA AT CHANDIGARH
BHUPINDER SINGH – Appellant
Versus
PRINCIPAL COMMISSIONER OF INCOME TAX CHANDIGARH – Respondent



IN THE HIGH COURT OF PUNJAB AND HARYANA AT CHANDIGARH Bhupinder Singh ….Petitioner versus Principal Commissioner of Income Tax Chandigarh and others …Respondents

1. The date when the judgment is reserved 01.12.2025 2. The date when the judgment is pronounced 17.12.2025 3. The date when the judgment is uploaded on the 19.12.2025 website

4. Whether only operative part of the judgment is Full pronounced or whether the full judgment is pronounced

5. The delay, if any, of the pronouncement of full Not judgment, and reasons thereof applicable CORAM: HON'BLE MR. JUSTICE DEEPAK SIBAL HON'BLE MS. JUSTICE LAPITA BANERJI Present: Ms. Radhika Suri, Senior Advocate with Mr. Abhinav Narang, Advocate and Ms. Parnika Singla, Advocate, for the petitioner.

Ms. Urvashi Dhugga, Senior Standing Counsel, Mr. Vidul Kapoor, Junior Standing Counsel and Ms. Kavita, Advocate, for the Income Tax Department.

Ms. Ameera Abdul Razak, Standing Counsel, for respondent No.2 (through Video Conferencing)

DEEPAK SIBAL, J.

1. Through the instant petition, the petitioner challenges order dated 08.09.2025, passed under Section 127(2) of the Income Tax Act, 1961 (for short – the 1961 Act) by the Principal Commissioner of Income Tax Chandigarh-I (for short – the PCIT, Chandigarh-I) transferring the jurisdiction of the petitioner to be assessed from DCIT Circle I (1), Chandigarh to ACIT/DCIT Central Circle, Panaji.

RELEVANT FACTS

2. On 08.01.2025 and other subsequent dates, search and survey proceedings under Sections 132 and 133A of the 1961 Act were conducted by the Income Tax authorities at various premises of M/s Blue Ocean Beverages Private Limited, Panaji, Goa (for short – M/s Blue Ocean). Since M/s Aaroha Alcobev Distribution Private Limited, New Delhi (for short – M/s Aaroha) was found to be one of the main distributors of M/s Blue Ocean, the search and survey proceedings of M/s Blue Ocean led to survey proceedings under Section 133A of the 1961 Act at the premises of M/s Aaroha. On the basis of evidence found against the petitioner during the afore search and survey proceedings, the petitioner was issued summons dated 26.03.2025 by DCIT/ADIT (Investigation), Panaji under Section 131(1A) of the 1961 Act as per which the petitioner was required to attend the office of the DDIT/ADIT(Investigation), Panaji on 31.03.2025 at 2.30 PM to produce either personally or through an authorized representative his books of accounts and other documents specified in such notice. In pursuance to the said summons the petitioner appeared before the concerned Revenue Officer at Panaji. Thereafter, through notice dated 08.07.2025, issued under Section 127(2) of the 1961 Act, by the PCIT, Chandigarh-I, the petitioner was granted an opportunity to show cause as to why his case for assessment be not centralized in Panaji. Through this notice the petitioner was informed that search and survey proceedings conducted under Section 132 and 133A of the 1961 Act at the business and residential premises of M/s Blue Ocean and its entire group had led to survey proceedings at the premises of M/s Aaroha wherein incriminating evidence had been found qua the petitioner of having received undisclosed cash amount of Rs.10 crores from Gaurav Sharma in connection with the sale of M/s Queen Distillers and Bottlers Private Limited, Chandigarh (for short- M/s Queen Distillers). Since the inquiry into organized/ systematic accounts/ fraud by M/s Blue Ocean was being conducted at Panaji and that evidence against the petitioner had also been found during the course of related survey proceedings which were all interlinked, an opportunity was granted to the petitioner to show cause as to why his case be not centralized to be considered alongwith other related cases at Panaji, Goa. Through his reply dated 09.07.2025 the petitioner objected to the transfer of his case from Chandigarh to Goa. He requested for being provided all documents/ material which formed the basis for transfer of his case and also sought personal

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