PR. COMMISSIONER OF INCOME TAX, DELHI vs. JANAK RAJ GUPTA AND COMPANY

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ITA/205/2026HC DelhiDLHC01132219202418 March 2026Bench: HON'BLE MR. JUSTICE VINOD KUMAR,HON'BLE MR. JUSTICE DINESH MEHTA1 pages
AI SummaryDismissed

What did the High Court hold?

The High Court of Delhi held that in view of the submission made by the learned counsel for the respondent (assessee) 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, the appeal along with any pending applications is dismissed. The reasoning is based on the established practice of the courts to dismiss appeals where the tax effect is below the prescribed monetary limits, as per the CBDT circulars which set the threshold for filing appeals by the revenue. The ratio decidendi is that appeals filed by the revenue with a tax effect below the stipulated monetary limits are not to be pursued, thereby conserving judicial time and resources. No issue was expressly left undecided.

What were the facts?

The appeal was filed by the Pr. Commissioner of Income Tax, Delhi (Appellant) against Janak Raj Gupta and Company (Respondent). The appeal was before the High Court of Delhi. The respondent's counsel submitted that the tax effect in the appeal was below the limits prescribed by CBDT Circular No. 5/2024 dated 15.03.2024 read with Circular No. 9/2024 dated 17.09.2024. The judgment does not specify the assessment year(s) or the specific order or action under challenge, nor the authority that passed it. The amount in dispute is also not recorded.

What were the issues?

1. Whether the appeal is maintainable in light of the tax effect falling below the monetary limits prescribed by CBDT Circulars. Assessee's Contention: The respondent (assessee) argued 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 the appeal should not proceed on this ground. Revenue's Contention: The judgment does not record any specific contention from the revenue regarding the maintainability of the appeal or any counter-argument to the assessee's submission on the tax effect.

AI-generated summary — verify with the full judgment below

$~47 * IN THE HIGH COURT OF DELHI AT NEW DELHI + ITA 205/2026 CM APPL. 16591/2026

PR. COMMISSIONER OF INCOME TAX, DELHI .....Appellant Through: Mr. Gaurav Gupta, SSC with Mr. Shivendra Singh, JSC, Mr. Yojit Pareek, JSC and Mr. Surya Jindal, Adv.

versus

JANAK RAJ GUPTA AND COMPANY .....Respondent Through: Mr. Salil Kapoor, Ms Soumya Singh and Ms Ananya Kapoor, Advs.

CORAM:

HON'BLE MR. JUSTICE DINESH MEHTA

HON'BLE MR. JUSTICE VINOD KUMAR

18.03.2026 O R D E R 1. Learned counsel for the respondent 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 along with the pending applications, if any, is dismissed.

DINESH MEHTA, J

VINOD KUMAR, J MARCH 18, 2026/dd 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 20/03/2026 at 13:10:19

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