What did the Tribunal hold?

The Tribunal held that the tax effect was below the monetary limit and no constitutional validity was involved, thus the Revenue's appeal was not maintainable.

The Revenue filed an appeal with a delay of 19 days, which was condoned. The assessee argued that the tax effect was below the monetary limit for appeals set by the CBDT.

What were the issues?

Whether the Revenue's appeal is maintainable when the tax effect is below the prescribed monetary limit and does not fall under any exceptions.

ACIT vs Krishna Chetty Govindaraju, Salem | ITAT Chennai 2026

Before: SHRI. INTURI RAMA RAO & BEFORE SHRI S.S. VISWANETHRA RAVI

Hearing: 18.06.2026Pronounced: 18.06.2026

आयकर अपीलीय अिधकरण, ’ ए’ �ायपीठ, चे�ई IN THE INCOME-TAX APPELLATE TRIBUNAL ‘A’ BENCH, CHENNAI �ी इंटूरी रामाराव, लेखा सद एवं �ी एस.एस. िव"ने$ रिव, �ाियक सद के सम% । BEFORE SHRI. INTURI RAMA RAO, ACCOUNTANT MEMBER AND BEFORE SHRI S.S. VISWANETHRA RAVI, JUDICIAL MEMBER आयकर अपील सं./I.T.A. No. 946/Chny/2026 िनधा'रण वष'/Assessment Year: 2018-19 Assistant Commissioner of Vs. Krishna Chetty Govindaraju, Income Tax, 2/142, Mel Chinthamaniyur Olapatti, 69A Race Course Road, Salem -636 455. Coimbatore. [PAN: AGAPG-3987-A] (अपीलाथ*/Appellant) (+,थ*/Respondent) अपीलाथ* की ओर से / Appellant by : Mr. S. Manoj Prakash, JCIT +,थ* की ओर से/Respondent by : Mr. Anandd Babunath, CA by virtual सुनवाई की तारीख/ Date of hearing : 18.06.2026 घोषणा की तारीख /Date of Pronouncement 18.06.2026 : आदेश /O R D E R PER S.S. VISWANETHRA RAVI, JUDICIAL MEMBER:

This appeal filed by the Revenue is directed against the order dated 25.12.2025 passed by the ld. Commissioner of Income Tax (Appeals), Chennai-20, for the assessment year 2018-19.

We find that this appeal was filed with a delay of 19 days. The assessee filed an affidavit explaining the reasons to condone the said

2 ITA No. 946/Chny/2026

delay. On perusal of the same and upon hearing both the parties, we find the reasons stated by the assessee are bonafide which really prevented the assessee in filing the appeal in time. Thus, delay of 19 days condoned.

When the appeal was taken up for hearing, the ld. AR Mr. Anandd

Babunath, CA submits that the tax effect in the appeal filed by the Revenue is less than the monetary limit of ₹.60,00,000/- fixed by the

CBDT to file an appeal by the Revenue before the Tribunal as per the

CBDT Circular No. 09/2024, dated 17.09.2024.

The ld. DR Shri S. Manoj Prakash, JCIT submits that even though

the tax effect in this case is below the monetary limit, further appeal in

this case has been preferred as this case fall in the exceptions to the

monetary limits specified in para 3.1(a) by relying upon the CBDT.

In reply, the ld. AR argued that no provision of the Act or the Rules

or notification issued there under has been held to be constitutionally

valid in this case and thus, the present case does not fall in the

exceptions specified in para 3.1(a) of the above said circular.

3 ITA No. 946/Chny/2026

Having heard both the parties and perused the material available on record, we note that the tax effect in this case is below the monetary limit and we are of the opinion that there is no constitutional validity involved on the issues on hand with regard to the tax effect and the monetary limits. Thus, the Revenue authorities are precluded from filing the appeal before the Tribunal, since the tax effect is less than ₹.60,00,000/- in this appeal. Thus, the appeal filed by the Appellant- Revenue is liable to be dismissed as not maintainable. Accordingly, the appeal filed by the Revenue is dismissed.

In the result, the appeal filed by the Revenue is dismissed. Order pronounced in the open Court on 18th June, 2026 at Chennai.

Sd/- Sd/- (INTURI RAMA RAO) (S.S. VISWANETHRA RAVI) ACCOUNTANT MEMBER JUDICIAL MEMBER

Chennai, Dated: 18.06.2026 JPV आदेश की +ितिलिप अ3ेिषत/Copy to: 1. अपीलाथ*/Appellant, 2.+,थ*/ Respondent, 3. आयकर आयु4/CIT, Chennai/Madurai/Coimbatore/Salem 4. िवभागीय +ितिनिध/DR & 5. गाड' फाईल/GF.

PRASANNA Digitally signed by PRASANNA VANI JETTY VANI JETTY Date: 2026.07.30 10:43:58 +05'30'

ASSISTANT COMMISSIONER OF INCOME TAX, COIMBATORE vs. KRISHNA CHETTY GOVINDARAJU, SALEM

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