SCOMMISSIONER OF INCOME TAX, D vs. M/S NATIONAL PANASONIC INDIA P

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ITA/1007/2005HC DelhiDLHC01058849200503 February 2026Bench: HON'BLE MR. JUSTICE DINESH MEHTA,HON'BLE MR. JUSTICE VINOD KUMAR1 pages
AI SummaryDismissed

What did the High Court hold?

The High Court held that the appeal is dismissed. The reasoning is based on the submission made by the appellant-department that the tax effect in the appeal falls below the monetary limits prescribed by the CBDT Circulars. The ratio decidendi is that appeals with a tax effect below the prescribed limits, as per CBDT circulars, are to be dismissed. The operative direction is the dismissal of the appeal. The appellant-department is granted liberty to move an application for revival of the appeal in case it falls within any of the exceptions mentioned in the circulars. No issue was expressly left undecided.

What were the facts?

The appeal was filed by the Commissioner of Income Tax (appellant) against M/s National Panasonic India Pvt. Ltd. (respondent). The assessment year(s) are not specified. The order or action under challenge is the appeal itself, filed before the Delhi High Court. The procedural history is that the learned counsel for the appellant submitted that the tax effect in the instant appeal falls below the limits prescribed in CBDT Circular No. 5/2024 dated 15.03.2024 read with Circular No. 9/2024 dated 17.09.2024. No amount in dispute is stated.

What were the issues?

1. Whether the appeal should be dismissed on the grounds of low tax effect as per CBDT Circulars No. 5/2024 and 9/2024? Assessee's contentions: The respondent (assessee) did not appear and no arguments were recorded on their behalf. Revenue's contentions: The learned counsel for the appellant (revenue) submitted that the tax effect in the instant appeal falls below the limits prescribed in CBDT Circular No. 5/2024 dated 15.03.2024 read with Circular No. 9/2024 dated 17.09.2024, implying that the appeal should be dismissed on this administrative ground.

AI-generated summary — verify with the full judgment below

$~66 * IN THE HIGH COURT OF DELHI AT NEW DELHI + ITA 1007/2005

SCOMMISSIONER OF INCOME TAX, D .....Appellant Through: Mr. Vipul Agrawal, SSC with Ms. Harshita Kotra, Adv.

versus

M/S NATIONAL PANASONIC INDIA P .....Respondent

Through: None.

CORAM:

HON'BLE MR. JUSTICE DINESH MEHTA

HON'BLE MR. JUSTICE VINOD KUMAR

O R D E R %

03.02.2026 1. Learned counsel for appellant submitted that the tax effect in the instant appeal falls below the limits prescribed in CBDT Circular No.5/2024 dated 15.03.2024 read with Circular No. 9/2024 dated 17.09.2024. 2. In view of the aforesaid, the appeal is dismissed. 3. The appellant-department shall be free to move application for revival of the appeal, in case it falls in any of the exceptions.

DINESH MEHTA, J.

VINOD KUMAR, J. FEBRUARY 3, 2026/sr

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 05/02/2026 at 12:16:54

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