What did the High Court hold?

The Delhi High Court rejected the department's appeal. The court held that the department could not take contradictory stands for different assessment years on the same set of facts and legal issues.

The Income Tax Department appealed a decision of the Income Tax Appellate Tribunal. The respondent argued that the department had not appealed a similar decision for a previous assessment year, which had attained finality.

What were the issues?

Whether the department can take inconsistent stands on the same legal and factual issues for different assessment years concerning the same assessee.

PCIT vs Humboldt Wedag India Pvt Ltd | Delhi High Court 2026

$~1 * IN THE HIGH COURT OF DELHI AT NEW DELHI + ITA 215/2024 PRINCIPAL COMMISSIONER OF INCOME TAX - 4 DELHI .....Appellant Through: Mr. Abhishek Maratha, SSC with Mr. Apoorv Agarwal, JSC. versus HUMBOLDT WEDAG INDIA PVT LTD .....Respondent Through: Mr. Arijit Chakarvarty, Adv. CORAM: HON'BLE MR. JUSTICE DINESH MEHTA HON'BLE MR. JUSTICE VINOD KUMAR O R D E R %

11.02.2026 1. Mr. Arijit Chakarvarty, learned counsel for the respondent at the outset submitted that the Income Tax Appellate Tribunal (hereinafter referred to as ‘the Tribunal’) had taken the same view for the assessment year 2016-17 and the Income Tax Department did not prefer any appeal against such order and the same has attained finality and on the basis of principle of consistency, this appeal be rejected. 2. Mr. Apoorv Agarwal, learned Junior Standing Counsel for the Department on instruction accepted the fact that no appeal has been filed against the above order dated 13.08.2021 referred by Mr. Chakarvarty that was passed for the previous assessment year 2016-17 in the assessee’s appeal. 3. Since, the Department has accepted the factual and legal position for assessment year 2016-17, we are of the firm view that since qua the basic 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 16/02/2026 at 12:48:14

issue of facts and law, the Department has accepted the position regardless the quantum of the tax involved (which was more than the limits prescribed in the circular issued by the CBDT), it should be taken that the Department has accepted the legal position. 4. The appellant-department cannot take two stands for different years on the same set of facts at least qua the same assessee. 5. The appeal is, therefore, rejected. DINESH MEHTA, J VINOD KUMAR, J FEBRUARY 11, 2026/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 16/02/2026 at 12:48:14

PRINCIPAL COMMISSIONER OF INCOME TAX - 4 DELHI vs. HUMBOLDT WEDAG INDIA PVT LTD

What did the High Court hold?

What were the facts?

What were the issues?

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