PR. COMMISSIONER OF INCOME TAX DELHI-4 vs. M/S GRUNER INDIA PVT LTD
What did the High Court hold?
The Tribunal decided that the appeal filed by the Revenue was to be dismissed. The reasoning was based on the submission made by the Revenue's counsel that the tax effect in the appeal was below the monetary limits prescribed by CBDT Circular No. 5/2024 and Circular No. 9/2024. The Tribunal accepted this submission and consequently dismissed the appeal. The ratio decidendi is that appeals with a tax effect below the prescribed monetary limits, as per CBDT circulars, are to be dismissed. The operative direction was the dismissal of the appeal. No issue was expressly left undecided.
What were the facts?
The appeal was filed by the Principal Commissioner of Income Tax, Delhi-4 (the Revenue) against an order presumably passed by the Income Tax Appellate Tribunal (though not explicitly stated in this excerpt). The respondent is M/s Gruner India Pvt Ltd (the Assessee). The appeal concerns an unspecified assessment year. The Revenue's counsel submitted that the tax effect in the instant appeal falls below the monetary limits prescribed in CBDT Circular No. 5/2024 dated 15.03.2024, read with Circular No. 9/2024 dated 17.09.2024. No arguments were presented by the Assessee.
What were the issues?
1. Whether the appeal filed by the Revenue is maintainable given the tax effect below the prescribed monetary limits as per CBDT Circulars No. 5/2024 and 9/2024. Assessee's Contentions: Not recorded. Revenue's Contentions: The Revenue, through its counsel, contended that the tax effect in the present appeal is below the threshold stipulated in the relevant CBDT Circulars, which would ordinarily warrant withdrawal or non-filing of such appeals. The Revenue relied on CBDT Circular No. 5/2024 dated 15.03.2024 and Circular No. 9/2024 dated 17.09.2024.
AI-generated summary — verify with the full judgment below
$~69 * IN THE HIGH COURT OF DELHI AT NEW DELHI + ITA 146/2026, CM APPL. 12090/2026 & CM APPL. 12091/2026 PR. COMMISSIONER OF INCOME TAX DELHI-4.....Appellant Through: Mr. Shlok Chandra, SSC, Ms. Naincy Jain and Ms. Madhavi Shukla, JSCs and Mr. Udit Dad, Adv. versus M/S GRUNER INDIA PVT LTD
.....Respondent Through: None CORAM: HON'BLE MR. JUSTICE DINESH MEHTA HON'BLE MR. JUSTICE VINOD KUMAR O R D E R %
23.02.2026 1. Mr. Shlok Chandra, learned Senior Standing Counsel for the appellant submitted that the tax effect in the instant appeal falls below the limit 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. DINESH MEHTA, J VINOD KUMAR, J FEBRUARY 23, 2026/cd 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 25/02/2026 at 15:25:13
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