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Pr. Commissioner of Income Tax-12, Delhi vs. Smt. Saloni Narang

Income Tax Appeal · 2026:DHC:7788-DBDecided 10 Sept 2026New Delhi Bench
ITA 437/2024CNR: DLHC010505912024
Justice Dinesh Mehta · Justice Rajneesh Kumar Gupta

Background

The tax department appealed against a Tribunal order that had allowed the assessee's appeal for Assessment Year 2006-07, with the Tribunal having relied on an earlier Delhi High Court ruling (PCIT v. Smt. Sneh Lata Sawhney) on a similar point of law.

Decision Breakdown

Before the department's counsel could even present arguments, the assessee's senior counsel pointed to a more recent Delhi High Court decision (PCIT v. Sanjay Jain, decided January 2026) that further elaborated on and reinforced the Sneh Lata Sawhney precedent, making the department's appeal untenable. The department's counsel could not counter this position, and the Court accordingly dismissed the appeal in light of the settled and reinforced legal position from these binding precedents.

Lesson Learnt

Once a legal question has been settled by binding precedent and reaffirmed in a later ruling, an appeal that simply repeats an argument already rejected by the courts is unlikely to succeed and may be summarily dismissed.

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