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.
Cases Discussed
- Principal Commissioner of Income Tax, Central-1, Delhi v. Smt. Sneh Lata Sawhney and Ors. — The Tribunal had relied upon this judgment while allowing the assessee’s appeal, and the High Court dismissed the Revenue’s appeal in light of the same judgment.
- Principal Commissioner of Income Tax, Central-1, Delhi v. Sanjay Jain reported in 2026:DHC:585-DB— Delhi High Court noted that Sneh Lata Sawhney had been followed and elaborated in this subsequent judgment and dismissed the Revenue’s appeal accordingly.
FULL TEXT OF THE JUDGMENT/ORDER OF DELHI HIGH COURT
1. The present appeal under Section 260A of the Income Tax Act, 1961 has been directed against the common judgment in the order dated 19.06.2023 passed by the Income Tax Appellate Tribunal, Bench “D” New Delhi (hereinafter referred to as “the Tribunal”), whereby the Tribunal has allowed appeals filed by the respondent/assessee for the Assessment Year (AY) 2006-07, 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.
2. Before Mr. Siddhartha Sinha, learned Senior Standing Counsel for the appellant could advance his submissions, Dr. Rakesh Gupta, learned Senior Counsel for the respondent, submitted that even if the best argument of the appellant is to be taken into account, the appellant’s appeal is anyway liable to be rejected, in view of the recent judgment of this Court rendered on 22.01.2026, in the case of Principal Commissioner of Income Tax, Central-1, Delhi v. Sanjay Jain reported in 2026:DHC:585-DB.
3. Mr. Siddhartha Sinha, learned Senior Standing Counsel for the appellant, is not in a position to controvert the aforesaid position of facts and law.
4. Having heard learned counsel for the parties, we are of the considered opinion that the appeal is liable to be dismissed in light of the judgment of this Court in the case of Sneh Lata Sawhney (supra) which has further been followed and elaborated by this Court in the case of Sanjay Jain (supra).
5. The appeal stands dismissed accordingly.
