PR. COMMISSIONER OF INCOME TAX-7, DELHI vs. PUNJAB NATIONAL BANK

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ITA - 17 / 2026HC Delhi15 January 20262 pages
For Petitioner: PUNEET RAI
AI SummaryPartly Allowed

What did the High Court hold?

The High Court admitted the appeal for hearing on the question of whether amounts transferred to blocked accounts and general reserve could be taxed as income. The other issues were not decided in this order.

What were the facts?

The Revenue filed an appeal against an ITAT decision. The appeal involved seven issues, with six decided in favor of the assessee and one pending. The High Court admitted the appeal on a specific question of law.

What were the issues?

Whether amounts transferred to blocked accounts and general reserve can be taxed as income.

AI-generated summary — verify with the full judgment below

$~76 * IN THE HIGH COURT OF DELHI AT NEW DELHI + ITA 17/2026 and CM APPL. 2547/2026, CM APPL. 2548/2026

PR. COMMISSIONER OF INCOME TAX-7, DELHI .....Appellant Through: Mr. Puneet Rai, Sr. Standing Counsel with Mr. Ashvini Kumar, SC.

versus

PUNJAB NATIONAL BANK

.....Respondent

Through: None.

CORAM:

HON'BLE MR. JUSTICE DINESH MEHTA

HON'BLE MR. JUSTICE VINOD KUMAR

O R D E R %

15.01.2026 CM APPL. 2547/2026(for exemption) 1. The instant application has been filed seeking exemption from furnishing typed copies. 2. For the reasons stated in the application, the exemption of furnishing typed copies is allowed. 3. Application stands disposed of. CM APPL. 2548/202 (for delay) 4. The instant application has been filed seeking condonation of delay of 34 days in filing the appeal. 5. Issue notice. 6. List on 20.04.2026 ITA 17/2026 7. Mr. Puneet Rai, learned Senior Standing Counsel for the appellant 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 11:50:47

fairly submits that appeal involves seven issues out of which six have been held against the Revenue and in favour of the assessee, while only one issue relating to disallowance on account of inter office adjustment remains to be decided and the same is pending for consideration in ITA 188/2013 and ITA 194/2024 between the very same parties. 8. While rejecting the appeal qua remaining issues, the instant appeal is admitted for the following question of law:- “b) Whether in the facts and circumstances of the case and in law, ITAT erred holding that Rs. 7,14,00,803/- transferred to blocked accounts and taken to general reserve through the profit and loss account cannot be taxed as income?”

9.

Admit. 10. Issue notice. 11. List this case on 20.04.2026.

DINESH MEHTA, J.

VINOD KUMAR, J. JANUARY 15, 2026/MR 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 11:50:47

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