ACIT, NEW DELHI vs. MSG FASHIONS PRIVATE LIMITED, NEW DELHI

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ITA 7575/DEL/2026Status: DisposedITAT Delhi19 August 2026AY 2014-153 pages
AI SummaryDismissed

What did the Tribunal hold?

The Tribunal noted that the tax effect in these appeals was below the threshold prescribed by the CBDT Circular No. 9/2024. The Departmental Representative conceded that the circular applied retrospectively to pending appeals.

What were the facts?

The Revenue filed three appeals against the CIT(A) orders for assessment years 2013-14, 2014-15, and 2015-16. The appeals involved proceedings under section 143(3) r.w.s. 147 of the Income-tax Act.

What were the issues?

Whether the appeals filed by the Revenue should be dismissed due to the tax effect being below the prescribed limit in the CBDT circular, considering its retrospective application.

Which sections of the Income-tax Act were involved?

Section 143(3),Section 147

AI-generated summary — verify with the full judgment below

Income Tax Appellate Tribunal, DELHI BENCH: “SMC” NEW DELHI

Before: SHRI SATBEER SINGH GODARA

For Appellant: Ms. Uma Upadhaya, CA
Hearing: 19.08.2026Pronounced: 19.08.2026

Heard together (3 matters)

ITA No. 7574/Del/2026
ITA No. 7575/Del/2026
ITA No. 7576/Del/2026

Read from the judgment's own cause title. This page is filed under one of them.

IN THE INCOME TAX APPELLATE TRIBUNAL, DELHI BENCH: “SMC” NEW DELHI BEFORE SHRI SATBEER SINGH GODARA, JUDICIAL MEMBER

ITA No. 7574/Del/2026, A.Y. 2013-14 ITA No. 7575/Del/2026, A.Y. 2014-15 ITA No. 7576/Del/2026, A.Y. 2015-16

ACIT Vs. MSG Fashions Private 419, 4th Floor Limited CR Building Near Shah Satnaam Ji IP Estate, Dham Begu Road, New Delhi Sirsa Haryana PAN: AAQCS4636K (Appellant) (Respondent)

Assessee by Ms. Uma Upadhaya, CA Department by Sh. Manoj Kumar, Sr. DR

Date of hearing 19.08.2026 Date of pronouncement 19.08.2026

ORDER These Revenue’s three appeals ITA No. 7574 – 7576/Del/2026 for assessment years 2013-14, 2014-15 & 2015-16, arise against the Commissioner of Income Tax (Appeals)/Addl./JCIT(A)-1, Mumbai [in short, the “CIT(A)”], orders dated 22.05.2026 involving proceedings under section 143(3) r.w.s. 147 of the Income-tax Act, 1961 (hereinafter referred to as ‘the Act’).

ITA No. 7574 to 7576/Del/2026

2.

Heard both the parties. Case file perused. 3. It emerges at the outset that the Revenue's instant appeals involve tax effect of Rs.13,58,434/-, 3,50,238/-, 13,58,434/- respectively i.e. less than the minimum tax effect prescribed of Rs.60 lakhs in the CBDT latest Circular No. 9/2024, dated 17.09.2024.

4.

Learned Departmental Representative is indeed very fair in not disputing the fact that the CBDT's foregoing tax effect circular has been made applicable with retrospective effect on all pending appeals as well. We thus reject the Revenue's instant three appeals for this precise reason subject to all just exceptions.

5.

These Revenue's three appeals ITA Nos. 7574- 7576/Del/2026 are dismissed in above terms. A copy of this common order be placed in the respective files. Order pronounced in the open court on 19/08/2026 Sd/- (SATBEER SINGH GODARA) JUDICIAL MEMBER Dated: 10/09/2026 Binita, Sr. PS Copy forwarded to: 1. Appellant 2. Respondent 3. CIT 4. CIT(A)

ITA No. 7574 to 7576/Del/2026

5.

DR Asst. Registrar, ITAT, New Delhi

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