High Court of Delhi · Judgments and reasoned final orders
Principal Commissioner of Income Tax-10 v. Dabur Invest Corp.
ITA 344/2026 ·
Dismissal of Revenue appeal for AY 2012-13 on principles of consistency where the identical issue had been consistently answered in favour of the assessee from AY 2002-03 to AY 2023-24 and the Revenue's appeal for AY 2015-16 (ITA 493/2025) had already been dismissed on 08.10.2025.
1. FACTS OF THE CASE
After condoning a 172-day delay in filing and a 191-day delay in re-filing, the High Court examined ITA 344/2026 challenging the ITAT Delhi Bench 'H' order dated 28.10.2024 for AY 2012-13, wherein the ITAT had followed its own earlier orders for AYs 2013-14, 2014-15, and 2015-16.
2. DISCUSSION BY THE COURT
Senior Standing Counsel for the Revenue fairly pointed out that the Revenue's appeal against the ITAT's relied-upon order for AY 2015-16 had already been dismissed by a coordinate bench on 08.10.2025 in ITA 493/2025 (which in turn followed ITA 482/2019 noting consistent adjudication in the assessee's favour from AY 2002-03 to AY 2023-24). Bearing in mind the principle of consistency and the absence of any distinguishing fact for AY 2012-13, no substantial question of law arose.
3. JUDICIAL DECISION
Following the order dated 08.10.2025 in ITA 493/2025, the High Court dismissed the Revenue's appeal.
4. OUTCOME
Assessee - Revenue appeal for AY 2012-13 dismissed on consistency.
5. AKHB REVIEW POINT
Where a recurring tax issue has been consistently decided in the assessee's favour across two decades of assessments (AYs 2002-03 to 2023-24) without any change in underlying facts, the High Court will dismiss subsequent departmental appeals on the rule of consistency.
Source and verification
3-page official High Court of Delhi judgment PDF (DLHC011104372025_1_2026-04-28.pdf, 204,445 bytes).
Original PDF: 3 pages · SHA-256: edd2fc03865013f91d4f01cbd779c1197b5bf33fb6f56d63ad5b4fc0725b0282
Supplied source-reviewed note retained; original bytes and identity validation checked in this release. Substantive re-review is not claimed for this record.
Applies Section 260A of the Income-tax Act, 1961 for AY 2012-13. Income-tax Act, 2025 equivalence is not verified.
Full 3-page primary judgment PDF text read and verified page-by-page. Follows PCIT v. Dabur Invest Corp. Ltd. (ITA 493/2025 decided 08.10.2025 and ITA 482/2019).
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