JOINT COMMISSIONER OF INCOME TAX (IN-SITU), CIRCLE-1, JAMSHEDPUR, JAMSHEDPUR vs. M/S NOODY AUTO PVT. LTD., ADITYAPUR

ITA 37/RAN/2025Status: DisposedITAT Ranchi20 April 20265 pages
AI SummaryDismissed

What did the Tribunal hold?

The Tribunal dismissed the Revenue's appeals for both assessment years, primarily on the grounds of low tax effect below the threshold prescribed by CBDT Circular No. 09/2024. The Tribunal also found that the CIT(A) had considered substantial evidence before deleting the additions, and the Revenue failed to point out any errors in the factual findings.

What were the facts?

The Revenue filed appeals against the CIT(A)'s orders for AY 2021-22 and 2022-23. The assessee argued that the appeals should be dismissed due to low tax effect, citing a CBDT circular. The CIT(A) had deleted additions made by the AO on grounds of turnover difference, cessation of liability, disallowances under Section 43B, and unexplained expenses/investments.

What were the issues?

Whether the Revenue's appeals are maintainable due to low tax effect, and whether the CIT(A) erred in deleting additions made by the AO after considering evidence.

Which sections of the Income-tax Act were involved?

Section 41(1),Section 43B,Section 69C

AI-generated summary — verify with the full judgment below

Income Tax Appellate Tribunal, RANCHI BENCH, RANCHI

Before: S/SHRI GEORGE MATHAN & RATNESH NANDAN SAHAY

For Appellant: Shri Nitin Pasari/Shubham Choudhary, ARs
For Respondent: Shri Ashish Kumar Deharia, ld CIT DR
Hearing: 20/04/2026Pronounced: 20/04/2026

Per Bench ITA No.37/Ran/2025 for the assessment year is an appeal filed by the revenue against the order of ld CIT(A), NFAC, Delhi dated 14.8.2024 in Appeal No.NFAC/2020-21/10209914. P a g e 1 | 5

ITA Nos. 37 & 52 /Ran/2025 C.O.No.1/Ran/2025 Assessment Years: 2021-22 & 2022-23

2.

At the outset, ld AR of the assessee submitted that the appeal of the revenue deserves to be dismissed due to low tax effect in view of the CBDT Circular No. No.09/2024 dated 17.9.2024, whereby the threshold limit for filing of appeals by the Revenue before the

The order continues below.

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