PRINCIPAL COMMISSIONER OF INCOME TAX, (CENTRAL)-1, DELHI vs. MOHD. SHAHNAWAZ

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ITA - 189 / 2026HC Delhi17 March 20262 pages
For Petitioner: PUNEET RAI
AI SummaryPartly Allowed

What did the High Court hold?

The Delhi High Court admitted the appeals for hearing. It framed substantial questions of law regarding the validity of common approval and whether any lapse was procedural or substantial.

What were the facts?

The appeals concern the validity of common approval granted by the Additional Commissioner of Income Tax for different Assessment Years. The Revenue has appealed against the decision of the ITAT.

What were the issues?

The key issues are whether a common approval for multiple assessment years is legally valid and if any procedural lapse would invalidate the assessment proceedings.

Which sections of the Income-tax Act were involved?

Section 56,Section 57,Section 58,Section 59,Section 68,Section 69,Section 70,Section 72,Section 73

AI-generated summary — verify with the full judgment below

$~56 to 59, 68, 69, 70, 72 & 73 * IN THE HIGH COURT OF DELHI AT NEW DELHI + ITA 188/2026 + ITA 189/2026 + ITA 190/2026 + ITA 191/2026 + ITA 194/2026 + ITA 195/2026 + ITA 196/2026 + ITA 198/2026 + ITA 199/2026 PRINCIPAL COMMISSIONER OF INCOME TAX, (CENTRAL)-1, DELHI .....Appellant Through: Mr. Puneet Rai, SSC with Mr.Ashvini Kr. & Mr. Rishabh Nangia, JSCs versus MOHD. SHAHNAWAZ MOIN AKHTAR QURESHI

.....Respondents Through:

CORAM: HON'BLE MR. JUSTICE DINESH MEHTA HON'BLE MR. JUSTICE VINOD KUMAR O R D E R %

17.03.2026 CM APPL. 16278/2026(exemption) CM APPL. 16282/2026(exemption) CM APPL. 16283/2026(exemption) CM APPL. 16287/2026(exemption) CM APPL. 16345/2026(exemption) CM APPL. 16348/2026(exemption) CM APPL. 16351/2026(exemption) CM APPL. 16364/2026(exemption) CM APPL. 16365/2026 (exemption) 1. Allowed, subject to all just exceptions. 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 13:13:59

2.

The applications stand disposed of. ITA 188/2026 ITA 189/2026 ITA 190/2026 ITA 191/2026 ITA 194/2026 ITA 195/2026 ITA 196/2026 ITA 198/2026 ITA 199/2026 3. The following substantial questions of law arise in the appeals:-

(i) Whether in the facts of the case, one common approval for different Assessment Years granted by the Additional Commissioner of Income Tax was contrary to law?

(ii) In case the answer to the first question is in the affirmative, whether the lapse is procedural or substantial warranting annulment of the assessment proceedings? 4. Admit. 5. Issue notice to the respondent returnable on 28.03.2026. 6. Notice be issued in two sets out of which one be given dasti to Mr.Puneet Rai, learned Senior Standing Counsel for the appellant, for effecting dasti service. DINESH MEHTA, J. VINOD KUMAR, J. MARCH 17, 2026 kk 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 13:13:59

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