What did the High Court hold?

The High Court noted the CIT(A)'s observation as the best way forward and found the ITAT's decision to allow the appeal untenable. The court ordered that the status quo be maintained until the next hearing.

The Revenue appealed against an ITAT order that allowed the assessee's appeal. The CIT(A) had suggested the assessee file a return for AY 2016-17 to claim a refund, believing the income was taxable in AY 2018-19. The ITAT, however, allowed the appeal despite this observation.

What were the issues?

Whether the ITAT erred in allowing the assessee's appeal when the CIT(A) had suggested a different course of action for claiming refunds and taxation.

CIT vs Marguerite Lasusa Chawla | Delhi High Court 2025

$~60 * IN THE HIGH COURT OF DELHI AT NEW DELHI + ITA 521/2025 COMMISSIONER OF INCOME TAX, INTERNATIONAL TAXATION-1, NEW DELHI .....Appellant Through: Mr. Puneet Rai, SSC, Mr. Gibran, JSC, Mr. Ashvini Kumar, Mr. Rishabh Nangia and Mr. Gibran, Advs. versus MARGUERITE LASUSA CHAWLA .....Respondent Through: None CORAM: HON'BLE MR. JUSTICE V. KAMESWAR RAO HON'BLE MR. JUSTICE VINOD KUMAR O R D E R %

15.10.2025 CM APPL. 64857/2025 1. Exemption allowed, subject to all just exceptions. 2. The application stands disposed of. CM APPL. 64859/2025 3. For the reasons stated in the application, the delay of 10 days in filing the appeal is condoned. 4. The application is disposed of. ITA 521/2025, CM APPL. 64858/2025 5. Issue notice through all permissible modes returnable on 28.04.2026. 6. Noting the submission made by Mr. Puneet Rai, Senior Standing Counsel by drawing our attention to page 56 of the paper-book, more This is a digitally signed order. The authenticity of the order can be re-verified from Delhi High Court Order Portal by scanning the QR code shown above. The Order is downloaded from the DHC Server on 27/03/2026 at 12:04:15

particularly paragraph 16 that the observation made by the CIT(A) depict the best way forward in the facts of this case but the ITAT despite such observation has allowed the appeal which is untenable: “16. As the appellant believes that the income is taxable in AY 2018-19, she may consider filing return for AY 2016-17 after obtaining necessary condonation in this regard from the appropriate authority and seek refund.” 7. In view of the above, status quo as of today, shall be maintained, till the next date of hearing. V. KAMESWAR RAO, J VINOD KUMAR, J OCTOBER 15, 2025 ss This is a digitally signed order. The authenticity of the order can be re-verified from Delhi High Court Order Portal by scanning the QR code shown above. The Order is downloaded from the DHC Server on 27/03/2026 at 12:04:15

COMMISSIONER OF INCOME TAX, INTERNATIONAL TAXATION-1, NEW DELHI vs. MARGUERITE LASUSA CHAWLA

What did the High Court hold?

What were the facts?

What were the issues?

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