PR. COMMISSIONER OF INCOME TAX-7, DELHI vs ATUL GOEL

Judgment text excerpt

$~50 * IN THE HIGH COURT OF DELHI AT NEW DELHI % Date of Decision : 12.01.2026 + ITA 10/2026 PR. COMMISSIONER OF INCOME TAX-7, DELHI .....Appellant Through: Mr. Puneet Rai, SSC, Mr. Gibran, JSC, Mr. Ashvini Kumar, Mr. Rishabh Nangia and Mr. Gibran, Advs. versus ATUL GOEL .....Respondent Through: Mr. Nischay Kantoor, Adv. CORAM: HON'BLE MR. JUSTICE DINESH MEHTA HON'BLE MR. JUSTICE VINOD KUMAR DINESH MEHTA, J. (ORAL) CM APPL. 1653/2026 (Exemption) 1. Exemption allowed, subject to all just exceptions. 2. The application stands disposed of. CM APPL. 1654/2026 (Delay of 43 Days in Filing) 3. For the reasons stated in the application seeking condonation of delay, the same is allowed. The delay of 43 days in filing the appeal is condoned. 4. The application stands disposed of. ITA 10/2026 5. The present appeal has been preferred under Section 260A of the Income Tax Act, 1961 (hereinafter referred to as ‘the Act of 1961’) against the order dated 10.05.2025, passed by the Income Tax Appellate Tribunal Delhi Bench “A”, Delhi (hereinafter referred to as ‘ITAT’) in an appeal filed ITA 10/2026 Page 1 of 4 Signature Not Verified Signed By:PRAMOD KUMAR VATS Signing Date:15.01.2026 15:09:11 by the appellant-Income Tax Department. Said appeal was heard along with the cross-objections which were filed by the respondent-assessee. 6. The issue involved in the present case is in relation to some transactions, which took place between the respondent and a broker, namely M/s Pace Commodity Broker Pvt. Ltd. While recording the reason, the Assessing Officer (AO) had clearly recorded that pursuant to investigation conducted by Serious Fraud Investigation Office (hereinafter referred to as ‘SFIO’), it has transpired that the respondent-assessee has been a beneficiary of Client Code Modification a