PR. COMMISSIONER OF INCOME TAX-12, DELHI vs. SMT. SALONI NARANG
What did the High Court hold?
The Delhi High Court, comprising Hon'ble Mr. Justice Dinesh Mehta and Hon'ble Mr. Justice Rajneesh Kumar Gupta, held that the appeal is liable to be dismissed. The Court's decision was based on the established precedent of this Court in the case of Smt. Sneh Lata Sawhney (supra). Furthermore, the Court noted that this precedent had been subsequently followed and elaborated upon in another judgment of the same Court in the case of Sanjay Jain (supra). The Revenue's counsel was unable to controvert the position of law as presented by the assessee's counsel, which relied on these High Court judgments. Consequently, the appeal filed by the Revenue against the ITAT's order was dismissed. The operative direction was the dismissal of the appeal.
What were the facts?
The appeal is filed by the Pr. Commissioner of Income Tax-12, Delhi (Revenue) against a common judgment dated 19.06.2023 passed by the Income Tax Appellate Tribunal (ITAT), Bench “D” New Delhi. The ITAT had allowed appeals filed by the respondent/assessee, Smt. Saloni Narang, for Assessment Year (AY) 2006-07. The ITAT's decision was based on a previous judgment of the Delhi High Court in the case of Principal Commissioner of Income Tax, Central-1, Delhi v. Smt. Sneh Lata Sawhney and Ors. The Revenue's appeal was heard by the Delhi High Court on 10.09.2026. The amount in dispute is not specified. The procedural history involves the ITAT's order allowing the assessee's appeals, which is now under challenge before the High Court.
What were the issues?
1. Whether the ITAT erred in allowing the appeal of the assessee for AY 2006-07, by relying on the judgment in Smt. Sneh Lata Sawhney's case, which is a question of law. Assessee's Contention: The respondent/assessee, through Dr. Rakesh Gupta, Sr. Adv., submitted that the appeal is liable to be rejected even considering the appellant's best arguments, in view of a recent judgment of the Delhi High Court dated 22.01.2026 in the case of Principal Commissioner of Income Tax, Central-1, Delhi v. Sanjay Jain. This judgment, according to the assessee, follows and elaborates upon the principles laid down in Smt. Sneh Lata Sawhney (supra). Revenue's Contention: The appellant, represented by Mr. Siddhartha Sinha, learned Senior Standing Counsel, was not in a position to controvert the position of facts and law presented by the assessee's counsel.
Which sections of the Income-tax Act were involved?
AI-generated summary — verify with the full judgment below
Cause title — parties, addresses and appearances
J U D G M E N T DINESH MEHTA, J. (ORAL)
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.
Before Mr. Siddhartha Sinha, learned Senior Standing Counsel for the ITA 437/2024 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.
Mr. Siddhartha Sinha, learned Senior Standing Counsel for the appellant, is not in a position to controvert the aforesaid position of facts and law.
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).
The appeal stands dismissed accordingly. DINESH MEHTA (JUDGE) RAJNEESH KUMAR GUPTA (JUDGE) SEPTEMBER 10, 2026 kk
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