High Court of Delhi · Judgments and reasoned final orders
Principal Commissioner of Income Tax, Central-1, Delhi v. Indrani Sathe & Subhash Sathe (Batch of 11 Appeals)
ITA Nos. 95, 96, 97, 98, 99, 100, 101, 102, 103, 104 & 105 of 2026 ·
Dismissal of 11 Revenue appeals for AYs 2006-07 to 2011-12 challenging ITAT order dated 29.05.2025 involving exchange-of-information / offshore account assessments under the India-Switzerland DTAA, following PCIT v. Smt. Sneh Lata Sawhney (2025:DHC:3617-DB) and PCIT v. Sanjay Jain (2026:DHC:585-DB).
1. FACTS OF THE CASE
The Revenue filed 11 appeals (ITA Nos. 95, 97, 98, 99, 101, 102 & 104/2026 against Indrani Sathe and ITA Nos. 96, 100, 103 & 105/2026 against Subhash Sathe) challenging the common order dated 29.05.2025 passed by the ITAT Delhi Bench 'G' for AYs 2006-07 to 2011-12, which had dismissed the Revenue's appeals following PCIT v. Smt. Sneh Lata Sawhney (2025:DHC:3617-DB).
2. DISCUSSION BY THE COURT
Counsel for the respondents pointed out that even the Revenue's best argument stood foreclosed by the Division Bench's recent judgment dated 22.01.2026 in PCIT, Central-1, Delhi v. Sanjay Jain (2026:DHC:585-DB), the only factual difference being that Sanjay Jain involved the treaty with Hong Kong whereas the present batch involved the treaty between India and Switzerland. The Division Bench concurred that all 11 appeals were squarely covered by Sneh Lata Sawhney as elaborated in Sanjay Jain.
3. JUDICIAL DECISION
Dismissing all 11 Revenue appeals and pending applications, the High Court affirmed the ITAT's common order dated 29.05.2025.
4. OUTCOME
Assessee - All 11 Revenue appeals (ITA Nos. 95 to 105 of 2026) dismissed.
5. AKHB REVIEW POINT
The Delhi High Court's rulings in Sneh Lata Sawhney (2025:DHC:3617-DB) and Sanjay Jain (2026:DHC:585-DB) govern multi-year search/reassessment batches for AYs 2006-07 to 2011-12 involving foreign treaty information requests across both the India-Hong Kong and India-Switzerland treaties.
Source and verification
3-page official High Court of Delhi judgment PDF (DLHC011095922025_1_2026-02-04.pdf, 75,583 bytes).
Original PDF: 3 pages · SHA-256: ef52a9175cda8364a005f768f118d4164166e816ab1f5ed846e35fd2cae977fa
Supplied source-reviewed note retained; original bytes and identity validation checked in this release. Substantive re-review is not claimed for this record.
Applies Sections 90, 153A, and 260A of the Income-tax Act, 1961 read with the India-Switzerland DTAA for AYs 2006-07 to 2011-12. Income-tax Act, 2025 equivalence is not verified.
Full 3-page primary judgment PDF text read and verified page-by-page. Follows PCIT v. Smt. Sneh Lata Sawhney (2025:DHC:3617-DB) and PCIT v. Sanjay Jain (2026:DHC:585-DB decided 22.01.2026).
AI disclosure and professional disclaimer
AI-assisted source review. Independent human approval is not represented.
General research only. Read the complete judgment and verify applicable law and subsequent treatment before reliance.