Facts of the Case

The present matter involved multiple appeals filed by the Principal Commissioner of Income Tax (Central)-2 against M/s Ravnet Solutions Pvt. Ltd. before the Delhi High Court. The appeals pertained to income tax matters; however, during the hearing, it was acknowledged that the tax effect involved in these appeals was below ₹1,00,00,000, which is the monetary threshold prescribed under CBDT Circular No. 17/2019 

Issues Involved

  • Whether the appeals filed by the Income Tax Department are maintainable when the tax effect is below the monetary limit prescribed by CBDT Circular No. 17/2019.

Petitioner’s Arguments (Revenue)

  • The Revenue preferred appeals against the respondent company in respect of income tax matters.
  • The appeals were filed notwithstanding the monetary threshold prescribed.

Respondent’s Arguments (Assessee)

  • None appeared on behalf of the respondent during the proceedings.

Court’s Findings / Order

  • The Court noted that the tax effect in the present appeals is below ₹1 crore, which is the threshold prescribed under CBDT Circular No. 17/2019.
  • In view of the binding nature of the said circular, the Court held that such appeals are not maintainable.
  • Accordingly, all the appeals were dismissed on account of low tax effect.

Important Clarification

  • The judgment reinforces that CBDT monetary limit circulars are binding on the Revenue authorities.
  • Appeals filed in violation of prescribed limits are liable to be dismissed without examining merits.
  • This applies even where multiple connected appeals are involved, if each falls below the threshold.

Sections Involved

  • CBDT Circular No. 17/2019 dated 08 August 2019
  • Monetary limit for filing appeals by the Income Tax Department

Link to download the order -https://delhihighcourt.nic.in/app/case_number_pdf/2020:DHC:3906-DB/MMH17112020ITA13092018_161205.pdf

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