PR. COMMISSIONER OF INCOME TAX-(CENTRAL)- 2 vs. M/S SAGA DEVELOPERS PVT. LTD.

ITA - 467 / 2022HC Delhi21 November 20222 pages

For Petitioner: ZOHEB HOSSAIN

AI SummaryDismissed

What did the High Court hold?

The Delhi High Court held that the appeals should be dismissed as not pressed on account of low tax effect. The reasoning was based on the appellant's (Revenue's) admission that the tax effect in the present appeals was below the threshold limit of Rs. 1,00,00,000/- as stipulated in Circular 17/2019 dated 8th August, 2019, issued by the Central Board of Direct Taxes. The operative direction was the dismissal of the appeals. No specific issues were decided on merits, and no part of the judgment was expressly left undecided.

What were the facts?

The appeals were filed by the Principal Commissioner of Income Tax (Central)-2 against orders concerning assessment years not specified in the judgment. The respondents are M/s Saga Developers Pvt. Ltd. and M/s Pyramid Realtors Pvt. Ltd. The appeals were presented before the Delhi High Court. The revenue's counsel acknowledged that the tax effect in these appeals was below the threshold limit of Rs. 1,00,00,000/- as per CBDT Circular 17/2019 dated August 8, 2019. No arguments were presented by the respondents.

What were the issues?

1. Whether the appeals should be dismissed on account of low tax effect, considering the monetary limits prescribed by CBDT Circular 17/2019? (Question of law) Assessee's Contentions: Not recorded. Revenue's Contentions: The learned counsel for the appellant (Revenue) admitted that the tax effect in the present appeals is lower than the threshold limit of Rs. 1,00,00,000/- stipulated in Circular 17/2019 dated 8th August, 2019, issued by the Central Board of Direct Taxes. Based on this admission, the Revenue implicitly argued that the appeals should be dismissed as not pressed on account of low tax effect.

AI-generated summary — verify with the full judgment below

$~58 & 59 * IN THE HIGH COURT OF DELHI AT NEW DELHI + ITA 467/2022 & C.M.No.49688/2022 PR. COMMISSIONER OF INCOME TAX-(CENTRAL)- 2 ..... Appellant Through: Mr.Zoheb Hossain, Sr.Standing Counsel for the Revenue with Mr.Vipul Agrawal and Mr.Parth Semwal, Advocates. versus M/S SAGA DEVELOPERS PVT. LTD. ..... Respondent Through: None + ITA 468/2022 & C.M.No.49689/2022 PR. COMMISSIONER OF INCOME TAX- (CENTRAL)- 2 ..... Appellant Through: Mr.Zoheb Hossain, Sr.Standing Counsel for the Revenue with Mr.Vipul Agrawal and Mr.Parth Semwal, Advocates. versus M/S PYRAMID REALTORS PVT. LTD. ..... Respondent Through: None CORAM: HON'BLE MR. JUSTICE MANMOHAN HON'BLE MS. JUSTICE MANMEET PRITAM SINGH ARORA O R D E R % 21.11.2022 Learned counsel for appellant admits that the tax effect in the present 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 14:00:45

appeals is lower than the threshold limit of Rs.1,00,00,000/- as stipulated in Circular 17/2019 dated 8th August, 2019 issued by the Central Board of Direct Taxes. Keeping in view the aforesaid, present appeals are dismissed as not pressed on account of low tax effect. MANMOHAN, J MANMEET PRITAM SINGH ARORA, J NOVEMBER 21, 2022 KA 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 14:00:45

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