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Revenue’s Assessment Limitation Appeal Dismissed Following Sneh Lata Sawhney: Delhi HC

Case Law Details

TaxGuru Citation
2026 taxguru.in 13878
Case Name
PCIT-12 Vs Smt. Saloni Narang (Delhi High Court)
Date of Judgement/Order
Only available for paid members
Related Assessment Year
2006-07
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PCIT-12 Vs Smt. Saloni Narang (Delhi High Court)

Summary: The Delhi High Court dismissed the Revenue’s appeal filed under Section 260A of the Income Tax Act, 1961 against the common judgment and order dated 19.06.2023 passed by the Income Tax Appellate Tribunal, Bench “D”, New Delhi, whereby the Tribunal had allowed the respondent/assessee’s appeal for Assessment Year 2006-07 by relying upon the Delhi High Court judgment in Principal Commissioner of Income Tax, Central-1, Delhi v. Smt. Sneh Lata Sawhney and Ors., reported in 2025:DHC:3617-DB.

Before the Revenue’s Senior Standing Counsel could advance his submissions, senior counsel for the respondent submitted that even if the appellant’s best argument were taken into account, the appeal was liable to be rejected in view of the Delhi High Court’s subsequent judgment dated 22.01.2026 in Principal Commissioner of Income Tax, Central-1, Delhi v. Sanjay Jain, reported in 2026:DHC:585-DB. The Revenue’s counsel was not in a position to controvert the stated position of facts and law. After hearing the parties, the High Court held that the appeal was liable to be dismissed in light of its judgment in Sneh Lata Sawhney, which had subsequently been followed and elaborated in Sanjay Jain. Accordingly, the Revenue’s appeal stood dismissed.

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Author Info

CA Sandeep Kanoi
Qualification: CA in Job / Business
Company: Taxguru Consultancy
Location: Mumbai, Maharashtra
Articles Published: 21,146

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