ITAT Enforces CBDT Threshold: Revenue's Rs. 12.82 Lakh Appeal Dismissed under Rs. 60 Lakh Limit [Read Order]
The tribunal clarified that the issues raised in the appeal remain open for examination in future proceedings, if necessary. It also left room for the Revenue to seek a recall of the order if the case falls under any exceptions mentioned in the CBDT circular
![ITAT Enforces CBDT Threshold: Revenues Rs. 12.82 Lakh Appeal Dismissed under Rs. 60 Lakh Limit [Read Order]](https://www.taxscan.in/wp-content/uploads/2025/05/CBDT-CBDT-announces-CBDT-announces-e-Dispute-Resolution-Scheme-Taxscan.jpg "ITAT Enforces CBDT Threshold: Revenues Rs. 12.82 Lakh Appeal Dismissed under Rs. 60 Lakh Limit [Read Order]")
The Income Tax Appellate Tribunal (ITAT), Pune Bench, dismissed an appeal filed by the Revenue Department citing the Central Board of Direct Taxes (CBDT) monetary limit for filing appeals. The appeal, involving a tax dispute of Rs. 12.82 lakh, fell below the Rs. 60 lakh threshold set by the CBDT, making it inadmissible. The case pertained to the Assessment Year 2017-18, where the...
The Income Tax Appellate Tribunal (ITAT), Pune Bench, dismissed an appeal filed by the Revenue Department citing the Central Board of Direct Taxes (CBDT) monetary limit for filing appeals. The appeal, involving a tax dispute of Rs. 12.82 lakh, fell below the Rs. 60 lakh threshold set by the CBDT, making it inadmissible.
The case pertained to the Assessment Year 2017-18, where the Assessing Officer (AO) had made an addition of Rs. 12.82 lakh under Section 69A of the Income Tax Act, 1961, treating it as unexplained investment.
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The National Faceless Appeal Centre (NFAC) had earlier deleted this addition in favor of Yousuf Abdul Sattar Pochi, prompting the Revenue to challenge the decision before the ITAT. However, during the hearing, the Departmental Representative could not dispute that the tax effect in the appeal was Rs. 10,14,491, which was significantly below the CBDT's prescribed limit of Rs. 60 lakh.
The ITAT, referencing CBDT Circular No. 09 of 2024 dated 17.09.2024, stated that appeals with a tax effect below Rs. 60 lakh should not be filed by the Revenue. The circular aims to reduce unnecessary litigation and streamline the appeal process. The tribunal's decision follows judicial precedents, including the Supreme Court's rulings in CIT vs. Suman Tea and Plywood Industries (1997) and PCIT vs. M/s. LG Electronics India Pvt. Ltd. (2018), where courts have consistently upheld the importance of adhering to monetary limits for tax appeals.
Dr. Manish Borad, the Accountant Member presiding over the case, noted that since the tax effect in this appeal was below the threshold, the appeal was not maintainable and deserved to be dismissed. The tribunal clarified that the issues raised in the appeal remain open for examination in future proceedings, if necessary. It also left room for the Revenue to seek a recall of the order if the case falls under any exceptions mentioned in the CBDT circular.
To Read the full text of the Order CLICK HERE
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