What did the Tribunal hold?

The Tribunal accepted the assessee's contention regarding the tax effect. Consequently, the revenue's appeal was dismissed due to low tax effect, rendering the assessee's cross-objection infructuous.

The revenue filed an appeal against the CIT(A)'s order concerning AY 2014-15. The assessee argued that the tax effect in the revenue's appeal was below the threshold for filing an appeal before the ITAT as per CBDT Circular No. 9/2024.

What were the issues?

Whether the tax effect in the revenue's appeal meets the threshold for filing an appeal before the ITAT as per CBDT Circular No. 9/2024.

DCIT vs Safran Helicopter Engines Asia… | ITAT Mumbai 2026

IN THE INCOME-TAX APPELLATE TRIBUNAL, MUMBAI “I” BENCH, MUMBAI BEFORE SMT BEENA PILLAI, JUDICIAL MEMBER AND SHRI BIJAYANANDA PRUSETH, ACCOUNTANT MEMBER ITA No.3205/MUM/2026 (AY: 2014-15) Dy. Commissioner of Income Tax vs. Safran Helicopter Engines Asia Pte. (IT)-4(2)(1) Ltd. Room No. 627, 6th Floor, Kautilya 63 Loyang Way Singapore, Singapore- Bhavan, BKC, Mumbai, Mumbai- 999999. 400051. PAN/GIR No: AADCT4343F (Appellant) (Respondent) Co. No.210/Mum/2026 (AY 2014-15) Safran Helicopter Engines Asia Pte. vs. Dy. Commissioner of Income Tax (IT)- Ltd. 4(2)(1) 63 Loyang Way Singapore, Room No. 627, 6th Floor, Kautilya Singapore-999999. Bhavan, BKC, Mumbai, Mumbai- 400051. PAN/GIR No: AADCT4343F (Appellant) (Respondent) Assessee by MS Vidhushi Maheshwari a/w Shri Jishaan Jain, Shri Mitesh Jain & Ms Shruti Desai Revenue by Shri Sridhar G. Menon (SR DR ) Date of Hearing 27.07.2026 Date of Pronouncement 31.07.2026 O R D E R PER BIJYANANDA PRUSETH, AM:

This appeal filed by the revenue and the cross appeal by the assessee

emanate from the order passed under section 250 of the Income-tax Act, 1961

(in short, ‘Act’) by the Commissioner of Income Tax, Appeal-58, Mumbai [in

short, ‘CIT(A)’], dated 23.01.2026 for the assessment year (AY) 2014-15.

ITA No.3205/MUM/2026 CO No.210/Mum/2026 Safran Helicopter Engines Asia Pte. Ltd.

AT the outset, the ld. AR submitted that the tax effect in the instant appeal

filed by the revenue is below Rs.60,00,000/- for filing appeal before the ITAT. He

submitted that the AO has erred in computing the tax liability by applying the rate

prescribed under the Income-tax Act, 1961 instead of the rate provided under the

India-Singapore tax treaty, despite having expressly acknowledged and accepted

at Para 7.3 of the Remand Report dated 06.10.2025 that the assessee is eligible

to claim the benefits of the India-Singapore tax treaty. Though the tax effect in

Form 36 is mentioned at Rs. 1,37,37,575/-, the tax effect ought to have been

computed at Rs.54,95,030/-, being 10% of Rs.5,49,50,300/-. The Ld. Sr. DR has not

rebutted the contention of the Ld. AR. Hence, the tax effect is Rs.54,95,030/- and

hence, the appeal is not liable to be admitted due to low tax effect as per the CBDT Circular No.9/2024 dated 17.09.2024. Accordingly, the appeal is dismissed.

CO No.210/Mum/2026 4. Since, the appeal of the revenue has been dismissed, the cross objection filed by the assessee is infructuous. 5. In the result, the appeal of the revenue is dismissed and cross objection is

treated as infructuous.

Order is pronounced on 31.07.2026.

Sd/- Sd/- (BEENA PILLAI) (BIJYANANDA PRUSETH) JUDICIAL MEMBER ACCOUNTANT MEMBER *Aniket Chand; Sr. PS MUMBAI Date: 31.07.2026 2

ITA No.3205/MUM/2026 CO No.210/Mum/2026 Safran Helicopter Engines Asia Pte. Ltd.

Copy of the Order forwarded to: 1. The Assessee 2. The Respondent 3. The CIT(A) 4. CIT 5. DR/AR, ITAT, MUMBAI 6. Guard File

By Order

Assistant Registrar ITAT, MUMBAI

DY. COMMISSIONER OF INCOME TAX (IT)-4(2)(1), MUMBAI vs. SAFRAN HELICOPTER ENGINES ASIA PTE. LTD., MUMBAI

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