PR. COMMISSIONER OF INCOME TAX vs. JANAK RAJ GUPTA

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ITA/247/2026HC DelhiDLHC01132223202425 March 2026Bench: HON'BLE MR. JUSTICE VINOD KUMAR,HON'BLE MR. JUSTICE DINESH MEHTA2 pages
AI SummaryDismissed

What did the High Court hold?

The High Court of Delhi, in view of the submission made by the learned counsel for the appellant (Revenue) that the tax effect in the instant appeals 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, has dismissed the appeals. The reasoning is directly based on the appellant's statement regarding the tax effect and the applicability of the aforementioned CBDT circulars, which set monetary thresholds for filing appeals. The ratio decidendi is that appeals with a tax effect below the prescribed limits, as per the relevant CBDT circulars, are to be dismissed. No specific issue was left undecided, as the appeals were disposed of on the preliminary ground raised by the Revenue.

What were the facts?

These are two appeals filed by the Principal Commissioner of Income Tax against the respondent, Janak Raj Gupta (in ITA 247/2026) and Janak Raj Gupta and Company (in ITA 248/2026). The appeals challenge orders passed by an authority, the details of which are not specified in the judgment. The procedural history leading to these appeals is not detailed. The core of the matter presented to the High Court is the tax effect of the disputed amounts, which the appellant's counsel stated falls below the limits prescribed by CBDT Circulars.

What were the issues?

1. Whether the appeals filed by the Revenue should be dismissed on the grounds that the tax effect falls below the monetary limits prescribed by CBDT Circular No.5/2024 dated 15.03.2024 read with Circular No. 9/2024 dated 17.09.2024. Assessee's Contention: The judgment does not record any specific contentions from the assessee's side as counsel's appearance was not received. Revenue's Contention: The learned counsel for the appellant (Revenue) submitted that the tax effect in the instant appeals 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 Revenue relied on these circulars to argue for dismissal.

AI-generated summary — verify with the full judgment below

$~41 & 42 * IN THE HIGH COURT OF DELHI AT NEW DELHI + ITA 247/2026 & CM APPL. 18768/2026

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

versus

JANAK RAJ GUPTA

.....Respondent Through: Counsel (appearance not received)

+ ITA 248/2026 & CM APPL. 18776/2026

PR. COMMISSIONER OF INCOME TAX-10, NEW DELHI

.....Appellant Through: Mr.Gaurav Gupta, SSC with Mr.Shivendra Singh & Mr. Yojit Pareek, JSCs and Mr. Surya Jindal, Adv.

versus

JANAK RAJ GUPTA AND COMPANY

.....Respondent Through: Counsel (appearance not received)

CORAM:

HON'BLE MR. JUSTICE DINESH MEHTA

HON'BLE MR. JUSTICE VINOD KUMAR

O R D E R %

25.03.2026 1. Learned counsel for appellant submitted that the tax effect in the instant appeals fall below the limits prescribed in CBDT Circular No.5/2024 dated 15.03.2024 read with Circular No. 9/2024 dated 17.09.2024. 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 30/03/2026 at 15:56:42

2.

In view of the aforesaid, the appeals are dismissed.

DINESH MEHTA, J

VINOD KUMAR, J MARCH 25, 2026 kk

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 30/03/2026 at 15:56:42

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