CBDT Circular Leads to Dismissal of Revenue’s Appeal: ITAT upholds Threshold Limit [Read Order]

The tribunal held that the appeal was not maintainable under the CBDT circular. The tribunal reaffirmed that the prescribed limits must be adhered to, ensuring that only cases with significant tax implications are litigated
CBDT Circular Leads - Dismissal - Revenue's Appeal - ITAT - Threshold Limit - taxscan

The Income Tax Appellate Tribunal ( ITAT ) Delhi Bench dismissed the appeal filed by the Deputy Commissioner of Income Tax ( DCIT ), Central Circle-27, New Delhi, against Shri Parasram Holdings Pvt. Ltd. for the assessment year 2020-21. The appeal challenged the order passed by the Commissioner of Income Tax (Appeals), Delhi-28 CIT(A) on 03.08.2023. The ITAT ruled that the appeal was not maintainable as the tax effect was below Rs.60 lakh, which is the prescribed monetary limit set by CBDT Circular No. 09 of 2024 dated 17.09.2024.

Shri Parasram Holdings Pvt. Ltd., the Respondent, a company based in Delhi, was the respondent in this appeal. The original assessment order was passed by the Assessing Officer (AO) on 30.09.2021 for the assessment year 2020-21. The Revenue had contested the CIT(A)’s order and sought a review of the decision. During the hearing on 09.01.2025, the ITAT examined the appeal and found that the tax effect in this case was less than Rs.60 lakh.

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The tribunal referred to CBDT Circular No. 09 of 2024, which mandates that appeals should not be pursued before the ITAT if the tax effect does not exceed the prescribed monetary limit. The circular aims to reduce unnecessary litigation and ensure efficient tax administration.

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The ITAT Bench comprised Shamim Yahya, ( Accountant Member ) and Sudhir Pareek ( Judicial Member ). The tribunal reviewed the case and determined that the appeal did not meet the required monetary threshold. The tribunal emphasized that CBDT guidelines must be followed strictly to prevent unnecessary tax disputes. Based on these findings, the ITAT dismissed the appeal filed by the Revenue. The tribunal held that the appeal was not maintainable under the CBDT circular. The tribunal reaffirmed that the prescribed limits must be adhered to, ensuring that only cases with significant tax implications are litigated.

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In Conclusion, the appeal was dismissed.

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