THE COMMISSIONER OF INCOME TAX - INTERNATIONAL TAXATION -1 vs. AMPHENOL FCI ASIA PTE LTD (FORMERELY KNOWN AS FCI ASIA PTE. LTD. )

ITA - 231 / 2025HC Delhi14 July 20251 pages

For Petitioner: RUCHIR BHATIA

AI SummaryDismissed

What did the High Court hold?

The Delhi High Court held that the tax effect involved in the present appeal was below the threshold limit of ₹2,00,00,000/- as stipulated in the Circular dated 17.09.2024. The Court also noted that the case was not covered by any of the exceptions set out in the circular. Consequently, the High Court dismissed the appeal on the ground of low tax effect. No decision was made on the merits of the ITAT's order.

What were the facts?

The Revenue, represented by the Commissioner of Income Tax - International Taxation -1, filed an appeal before the Delhi High Court against an order dated 21.11.2023 passed by the Income Tax Appellate Tribunal (ITAT) in ITA No.9659/Del/2019. The appeal pertained to the assessment year 2015-16. The respondent in the appeal was Amphenol FCI Asia Pte Ltd (formerly known as FCI Asia Pte. Ltd.). The appeal was filed by the Revenue challenging the decision of the ITAT.

What were the issues?

1. Whether the present appeal filed by the Revenue is maintainable given the tax effect involved? The Revenue argued that the tax effect in the present appeal is below the threshold limit of ₹2,00,00,000/- as stipulated in Circular dated 17.09.2024 and is not covered by any exceptions mentioned in the circular. The Revenue's contention was that due to the low tax effect, the appeal should be dismissed.

AI-generated summary — verify with the full judgment below

$~58 * IN THE HIGH COURT OF DELHI AT NEW DELHI + ITA 231/2025 and CM APPL. 40940/2025 THE COMMISSIONER OF INCOME TAX - INTERNATIONAL TAXATION -1 .....Appellant Through: Mr Ruchir Bhatia, SSC, Mr Anant Mann, JSC Ms Aditi Sabharwal and Mr Abhishek Anand, Advocates. versus AMPHENOL FCI ASIA PTE LTD (FORMERELY KNOWN AS FCI ASIA PTE. LTD. ) .....Respondent Through: Ms Ananya Kapoor, Advocate. CORAM: HON'BLE MR. JUSTICE VIBHU BAKHRU HON'BLE MR. JUSTICE TEJAS KARIA O R D E R % 14.07.2025 1. The Revenue has filed the present appeal impugning the order dated 21.11.2023 passed by the learned Income Tax Appellate Tribunal in ITA No.9659/Del/2019 for the assessment year 2015-16. 2. At the outset, the learned counsel appearing for the Revenue states that the tax effect involved in the present appeal is below the threshold limit of ₹2,00,00,000/- as stipulated in the Circular dated 17.09.2024 and is not covered by any exceptions as set out in the circular. 3. Accordingly, the present appeal is dismissed on account of low tax effect. VIBHU BAKHRU, J TEJAS KARIA, J JULY 14, 2025/tr This is a digitally signed order. The authenticity of the order can be re-verified from Delhi High Court Order Portal by scanning the QR code shown above. The Order is downloaded from the DHC Server on 27/03/2026 at 13:11:52

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