PR. COMMISSIONER OF INCOME TAX- (CENTRAL)- 2 vs. M/S PYRAMID REALTORS PVT. LTD.
What did the High Court hold?
The High Court, upon being informed by the revenue's counsel that the tax effect in the appeals was below the monetary threshold prescribed by CBDT Circular 17/2019, decided to dismiss the appeals. The reasoning was based on the principle that appeals with a low tax effect, as defined by the circular, are not to be pressed. The operative direction was the dismissal of the appeals. No issues were left undecided; the decision was based on the admitted low tax effect.
What were the facts?
The appeals were filed by the Principal Commissioner of Income Tax (Central)-2 against orders concerning M/s Saga Developers Pvt. Ltd. and M/s Pyramid Realtors Pvt. Ltd. The appeals were before the Delhi High Court. The revenue was represented by its counsel, while the respondents (assessees) were not represented. The core of the matter revolved around the tax effect of the appeals.
What were the issues?
1. Whether the appeals should be dismissed on the grounds of low tax effect, considering the threshold limit stipulated in CBDT Circular 17/2019? (Question of law) Assessee's Contention: Not recorded. Revenue's Contention: The revenue's counsel admitted that the tax effect in the present appeals was 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.
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 14:00:30
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 14:00:30
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