PCIT-Central- 1 Vs Indrani Sathe (Delhi High Court)
The Delhi High Court dismissed Revenue appeals filed against a common order dated 29.05.2025 passed by the Income Tax Appellate Tribunal, Bench “G”, New Delhi, concerning Assessment Years 2006-07 to 2011-12. The Tribunal had rejected the Department’s appeals by relying on the Court’s earlier judgment in Sneh Lata Sawhney (2025:DHC:3617-DB). During the hearing, counsel for the respondent submitted that even assuming the best possible arguments for the Revenue, the appeals were liable to be rejected in view of the Court’s recent judgment dated 22.01.2026 in Sanjay Jain (2026:DHC:585-DB). It was pointed out that the only distinction between Sanjay Jain and the present matter was that the former involved the India–Hong Kong treaty, whereas the present case concerned the India–Switzerland treaty. After hearing the parties, the Court held that the appeals were liable to be dismissed in light of its judgment in Sneh Lata Sawhney, which had been followed and elaborated upon in Sanjay Jain. Accordingly, all the appeals and pending applications were dismissed.
FULL TEXT OF THE JUDGMENT/ORDER OF DELHI HIGH COURT
1. Present appeal has been directed against the common judgment in the order dated 29.05.2025 passed by the learned Income Tax Appellate Tribunal, Bench “G” New Delhi (hereinafter referred to as “the Tribunal”), whereby the Tribunal has rejected appeals filed by the Department for the Assessment Year (AY) 2006-07 to 2011-12, while relying upon judgment of this Court rendered in the case of Principal Commissioner of Income Tax, Central-1, Delhi v. Smt. Sneh Lata Sawhney and Ors. reported in 2025:DHC:3617-DB.
