DCIT, EXEMPTION CIRCLE, GZB, GHAZIABAD vs. SATYAM EDUCATIONAL SOCIETY, ROORKEE COLLEGE OF ENGINEERING

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ITA 7902/DEL/2025Status: DisposedITAT Delhi20 May 2026AY 2018-193 pages

In favour of the assessee: the Revenue's appeal was dismissed. From the AI summary of this appeal.

AI SummaryDismissed

What did the Tribunal hold?

The Tribunal dismissed the Revenue's appeals due to low tax effect, as they did not fall under any exception clause of the relevant CBDT circular. Consequently, the assessee's cross objections were rendered infructuous and also dismissed.

What were the facts?

The Revenue filed appeals against the CIT(A)'s order concerning Assessment Years 2018-19 and 2019-20. The tax effect for both assessment years was below the prescribed limit as per CBDT Circular No. 9/2024.

What were the issues?

The primary issue was whether the appeals filed by the Revenue should be dismissed on the grounds of low tax effect as per CBDT guidelines.

Which sections of the Income-tax Act were involved?

Section 154,Section 250,Section 147,Section 144B

AI-generated summary — verify with the full judgment below

Income Tax Appellate Tribunal, DELHI BENCH ‘E’, NEW DELHI

Before: SH. SATBEER SINGH GODARA & SH. NAVEEN CHANDRA

For Appellant: Shri Rajeev Ahuja, Adv, Shri Harshit Ahuja, Adv. and Shri S. K. Gupta, C.A
For Respondent: Ms. Ankush Kalra, Sr. D.R
Hearing: 20.05.2026Pronounced: 20.05.2026

Heard together (3 matters)

ITA No.7902/Del/2025
ITA No.7903/Del/2025
CO No.9/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 ‘E’, NEW DELHI BEFORE SH. SATBEER SINGH GODARA, JUDICIAL MEMBER AND SH. NAVEEN CHANDRA, ACCOUNTANT MEMBER ITA No.7902/Del/2025 [For A.Y. 2018-19] ITA No.7903/Del/2025 [For A.Y. 2019-20] DCIT Vs. Satyam Educational Society 5th KM Canal Road Exemption Circle – GZB Bajuheri, Mehwarkalan, Haridwar – 247 667 Haryana PAN : AAEAS 2646 B (APPELLANT) (RESPONDENT) And CO No.9/Del/2026 [Arising out of ITA No.7902/Del/2025] [For A.Y. 2018-19] CO No.8/Del/2026 [Arising out of ITA No.7903/Del/2025] [For A.Y. 2019-20]

Satyam Educational Society Vs. DCIT 5th KM Canal Road Exemption Bajuheri, Mehwarkalan, Circle – GZB Haridwar – 247 667 Haryana PAN : AAEAS 2646 B (APPELLANT) (RESPONDENT) Assessee by Shri Rajeev Ahuja, Adv., Shri Harshit Ahuja, Adv. and Shri S. K. Gupta, C.A. Revenue by Ms. Ankush Kalra, Sr. D.R. Date of hearing: 20.05.2026 Date of Pronouncement: 20.05.2026

ITA Nos.7902 & 7903/Del/2025 CO Nos.9 & 8/Del/2026 Satyam Educational Society [For A.Ys. 2018-19 & 2019-20] ORDER PER NAVEEN CHANDRA, ACCOUNTANT MEMBER :

The above captioned two appeals by the Revenue and Cross Objection by the assessee are preferred against order of the ld. Commissioner of Income Tax (Appeals) – NFAC, Delhi dated 17.09.2025 under section 154 r.w.s 250 of the Income Tax Act 1961 (herein after referred as ‘the Act’) arising from the assessment order dated 17.09.2025, passed by the Assessing Officer under Section 147 read with section 144B of the Income Tax Act, 1961 (‘the Act’) concerning Assessment Years 2018-19 & 2018-19. 2. Since the underlying facts are common in the cross objections of the assessee and Revenue and pertain to same assessee, they were heard together and are disposed of by this common order for the sake of convenience and brevity. 3. At the very outset, it was informed that the tax effect for the A.Y. 2018-19 is Rs.47,25,452/- and for the A.Y. 2019-20 is Rs.43,66,955/-, respectively. The tax effect for both the AYs are therefore below the prescribed limit as prescribed in the CBDT Circular No. 9/2024 dated 17.09.2024. Further, we are not apprised of any facts that these appeals fall under any exception clause of the said Circular. These appeals are accordingly, dismissed with liberty to the

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ITA Nos.7902 & 7903/Del/2025 CO Nos.9 & 8/Del/2026 Satyam Educational Society [For A.Ys. 2018-19 & 2019-20] revenue to approach the Tribunal as per the provisions of law, should it feel that the tax effect is more than Rs. 60 lakhs. CO Nos.9 & 8/Del/2026 : 4. As the appeals filed by the Revenue in ITA Nos.7902 & 7903/Del/2025 for A.Ys. 2018-19 & 2019-20, herein above have been dismissed on account of low tax effect, the cross objections filed by the assessee have become infructuous and likewise dismissed.

5.

In the result, both the appeals filed by the Revenue are dismissed and cross objections filed by the assessee is dismissed. Order pronounced in the open court on 20.05.2026

Sd/- Sd/- (SATBEER SINGH GODARA) (NAVEEN CHANDRA) JUDICIAL MEMBER ACCOUNTANT MEMBER Date:- 27.05.2026 Priti Yadav, Sr. Ps* Copy forwarded to: 1. Appellant 2. Respondent 3. CIT 4. CIT(Appeals) 5. DR: ITAT ASSISTANT REGISTRAR ITAT NEW DELHI

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