THE COMMISSIONER OF INCOME TAX - INTERNATIONAL TAXATION -1 vs. AMPHENOL FCI ASIA PTE LTD (FORMERELY KNOWN AS FCI ASIA PTE. LTD. )

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ITA/231/2025HC DelhiDLHC01120163202414 July 2025Bench: HON'BLE MR. JUSTICE VIBHU BAKHRU,HON'BLE MR. JUSTICE TEJAS KARIA1 pages
AI SummaryDismissed

What did the High Court hold?

The High Court of Delhi held that the present appeal filed by the Revenue is dismissed on account of low tax effect. The Court noted the statement made by the learned counsel for the Revenue that the tax effect involved in the appeal is below the threshold limit of ₹2,00,00,000/- as stipulated in the Circular dated 17.09.2024 and is not covered by any exceptions. Consequently, the appeal was not pressed on merits and was disposed of on this preliminary ground. No decision was made on the substantive issues that might have been raised before the ITAT.

What were the facts?

The Revenue, represented by the Commissioner of Income Tax - International Taxation -1, filed an appeal before the High Court of Delhi. The appeal challenged an order dated 21.11.2023 passed by the Income Tax Appellate Tribunal (ITAT) in ITA No.9659/Del/2019. This order pertained to the assessment year 2015-16. The assessee is Amphenol FCI Asia Pte Ltd (formerly known as FCI Asia Pte. Ltd.). The procedural history leading to the High Court appeal involved the ITAT's decision, which is now under challenge by the Revenue.

What were the issues?

1. Whether the present appeal filed by the Revenue is maintainable given the tax effect involved, in light of the Circular dated 17.09.2024. The Revenue argued that the tax effect in the present appeal is below the threshold limit of ₹2,00,00,000/- stipulated in the Circular dated 17.09.2024 and does not fall under any of the exceptions mentioned therein. Therefore, the appeal is not maintainable. The judgment does not record any arguments from the assessee on this specific issue.

AI-generated summary — verify with the full judgment below

$~58 * IN THE HIGH COURT OF DELHI AT NEW DELHI + ITA 231/2025 and CM APPL. 40940/2025 THE COMMISSIONER OF INCOME TAX - INTERNATIONAL TAXATION -1 .....Appellant Through: Mr Ruchir Bhatia, SSC, Mr Anant Mann, JSC Ms Aditi Sabharwal and Mr Abhishek Anand, Advocates. versus AMPHENOL FCI ASIA PTE LTD (FORMERELY KNOWN AS FCI ASIA PTE. LTD. ) .....Respondent Through: Ms Ananya Kapoor, Advocate. CORAM: HON'BLE MR. JUSTICE VIBHU BAKHRU HON'BLE MR. JUSTICE TEJAS KARIA O R D E R % 14.07.2025 1. The Revenue has filed the present appeal impugning the order dated 21.11.2023 passed by the learned Income Tax Appellate Tribunal in ITA No.9659/Del/2019 for the assessment year 2015-16. 2. At the outset, the learned counsel appearing for the Revenue states that the tax effect involved in the present appeal is below the threshold limit of ₹2,00,00,000/- as stipulated in the Circular dated 17.09.2024 and is not covered by any exceptions as set out in the circular. 3. Accordingly, the present appeal is dismissed on account of low tax effect. VIBHU BAKHRU, J TEJAS KARIA, J JULY 14, 2025/tr 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 16/07/2025 at 12:37:56

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