Dismissed¶32

The Pr. Commissioner of Income Tax -Central -1 v. Indrani Sathe

Delhi HC4 Feb 2026ITA/98/2026

Case brief

AI extract

What is this about?

Delhi High Court; ITA 95/2026 to ITA 105/2026 with connected CM APPLs.; Pr. Commissioner of Income Tax Central-1 (appellant; Ruchir Bhatia, SSC) v. Indrani Sathe and Subhash Sathe (respondents); ITAT Bench 'G' New Delhi order dated 29.05.2025 rejecting Department appeals for AY 2006-07 to 2011-12; India-Switzerland treaty contrasted with India-Hong Kong treaty in Sanjay Jain; appeals dismissed in light of Sneh Lata Sawhney 2025:DHC:3617-DB as followed and elaborated by Sanjay Jain 2026:DHC:585-DB; Justice Dinesh Mehta (oral) with Justice Vinod Kumar; decided 4 February 2026.

What did the court decide?

Having heard learned counsel for the parties, the Court was of the considered opinion that these appeals are liable to be dismissed in light of the judgment of this Court in Sneh Lata Sawhney (supra). ¶27

The Pr. Commissioner of Income Tax -Central -1 Vs Indrani Sathe — Delhi HC (2026) — LawSathi Research

¶1

$~225 to 235

¶2

IN THE HIGH COURT OF DELHI AT NEW DELHI

¶3

% Date of decision: 4^th February, 2026

¶4

- ITA 95/2026 & CM APPL. 7703/2026

¶5

- ITA 97/2026 & CM APPL. 7707/2026

¶6

- ITA 98/2026 & CM APPL. 7708/2026

¶7

- ITA 99/2026 & CM APPL. 7712/2026

¶8

- ITA 101/2026 & CM APPL. 7720/2026

¶9

- ITA 102/2026 & CM APPL. 7721/2026 + ITA 104/2026 & CM APPL. 7728/2026

¶10

THE PR. COMMISSIONER OF INCOME TAX -CENTRAL -1

¶11

.....Appellant Through: Mr. Ruchir Bhatia, SSC with Mr. Anant Mann, Mr. Pratyash Gupta & Mr. Pranjal Singh, Advs. versus

¶12

INDRANI SATHE .....Respondent Through: Mr. Prakash Chand Yadav, Mr. Manj Bala Yadav & Mr. Manish Yadav, Advs.

¶13

- ITA 96/2026 & CM APPL. 7706/2026 + ITA 100/2026 & CM APPL. 7714/2026

¶14

- ITA 103/2026 & CM APPL. 7722/2026 + ITA 105/2026 & CM APPL. 7737/2026

¶15

THE PR. COMMISSIONER OF INCOME TAX -CENTRAL -1

¶16

.....Appellant Through: Mr. Ruchir Bhatia, SSC with Mr. Anant Mann, Mr. Pratyash Gupta & Mr. Pranjal Singh, Advs.

¶17

versus

¶18

SUBHASH SATHE .....Respondent Through: Mr. Prakash Chand Yadav, Mr. Manj Bala Yadav & Mr. Manish Yadav, Advs.

¶19

ITA 95/2026 & other connected matters Page 1 of 3

¶20

Signature Not Verified Digitally Signed By:NAVEEN KUMAR Signing Da te:0 7.02.2026 13:19:36

¶21

CORAM: HON'BLE MR. JUSTICE DINESH MEHTA HON'BLE MR. JUSTICE VINOD KUMAR

¶22

J U D G M E N T

¶23

DINESH MEHTA, J. (Oral)

¶24

Present appeal has been directed against the common judgment in the order dated 29.05.2025 passed by the learned Income Tax Appellate Tribunal, Bench “G” New Delhi (hereinafter referred to as “the Tribunal”) , whereby the Tribunal has rejected appeals filed by the Department for the Assessment Year (AY) 2006-07 to 2011-12, while relying upon judgment of this Court rendered in the case of Principal Commissioner of Income Tax, Central-1, Delhi v. Smt. Sneh Lata Sawhney and Ors. reported in 2025:DHC:3617-DB .

¶25

Before Mr. Ruchir Bhatia, learned Senior Standing Counsel for the appellant could advance his submissions, learned counsel for the respondent invited Court’s attention that even if the best argument of the appellant is to be taken into account, the appellant’s appeals are anyway liable to be rejected, in view of the recent judgment of this Court rendered on 22.01.2026, in the case of Principal Commissioner of Income Tax, Central-1, Delhi v. Sanjay Jain reported in 2026:DHC:585-DB.

¶26

He submitted that the only difference in the case of Sanjay Jain (supra) is that the treaty in question was between India and Hong Kong, whereas in the instant case the treaty is between India and Switzerland. He prayed that all these appeals be dismissed.

¶27

Having heard learned counsel for the parties, we are of the considered opinion that these appeals are liable to be dismissed in light of the judgment

¶28

Signature Not Verified

¶29

ITA 95/2026 & other connected matters Page 2 of 3

¶30

Digitally Signed By:NAVEEN KUMAR Signing Da te:0 7.02.2026 13:19:36

¶31

of this Court in the case of Sneh Lata Sawhney (supra) which has further been followed and elaborated by this Court in the case of Sanjay Jain (supra).

¶32