Revenue's Appeal Dismissed by Delhi High Court: Limitation on Assessment Upheld Under Section 260A
Overview of the Case
The Delhi High Court dismissed an appeal filed by the Revenue under Section 260A of the Income Tax Act, 1961, pertaining to Assessment Year 2006-07. The case — PCIT-12 Vs Smt. Saloni Narang (ITA 437/2024), decided on 15.09.2026 — arose from a challenge to a common order of the Income Tax Appellate Tribunal, Bench "D", New Delhi, dated 19.06.2023, wherein the Tribunal had ruled in favour of the assessee.
The dismissal was grounded in binding precedents already established by the Delhi High Court itself, leaving the Revenue with no sustainable legal ground to pursue the appeal further.
Background: What Happened Before the Court
The Tribunal's Decision
The Income Tax Appellate Tribunal, Bench "D", New Delhi, through its order dated 19.06.2023, allowed the appeals filed by the respondent/assessee for Assessment Year 2006-07. In doing so, the Tribunal placed reliance on the Delhi High Court's judgment in Principal Commissioner of Income Tax, Central-1, Delhi v. Smt. Sneh Lata Sawhney and Ors., reported in 2025:DHC:3617-DB.
The Tribunal's finding, built on the foundation of Sneh Lata Sawhney, effectively meant that the Revenue's position — whether on facts or on law — could not be sustained in light of that judicial precedent.
Revenue's Appeal Under Section 260A
Aggrieved by the Tribunal's order, the Revenue filed an appeal before the Delhi High Court under Section 260A of the Income Tax Act, 1961, which provides a statutory mechanism for filing appeals before the High Court on substantial questions of law arising from ITAT orders.
Proceedings Before the Delhi High Court
Pre-Hearing Submissions by Respondent's Counsel
Before the Revenue's counsel — Mr. Siddhartha Sinha, learned Senior Standing Counsel for the appellant — could even begin advancing arguments on behalf of the Revenue, Dr. Rakesh Gupta, learned Senior Counsel appearing for the respondent/assessee, intervened with a preliminary submission.