PR. COMMISSIONER OF INCOME TAX -7 vs. M/S TCK ADVISERS PVT. LTD.
What did the High Court hold?
The High Court held that in view of the submission made by the learned counsel for the appellant (Revenue) 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 administrative policy of the CBDT regarding the threshold for filing appeals, which the Revenue itself brought to the court's attention. The ratio decidendi is that appeals with a tax effect below the prescribed monetary limits, as per relevant CBDT circulars, are to be dismissed. The operative direction is the dismissal of the appeal.
What were the facts?
The appeal was filed by the Pr. Commissioner of Income Tax -7 (appellant) against M/s TCK Advisers Pvt. Ltd. (respondent). The appeal challenges an order or action from an unspecified authority for assessment year(s) not mentioned in the judgment. The amount in dispute is also not stated. The procedural history is limited to the filing of the appeal before the High Court. The appellant's counsel 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.
What were the issues?
1. Whether the appeal should be dismissed on the grounds that the tax effect is below the prescribed monetary limits as per CBDT Circulars No. 5/2024 and 9/2024. Assessee's contentions: Not recorded in the judgment. Revenue's contentions: The revenue, through its counsel, 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
$~77 * IN THE HIGH COURT OF DELHI AT NEW DELHI + ITA 44/2026, CM APPL. 4569/2026
PR. COMMISSIONER OF INCOME TAX -7 .....Appellant
Through: Mr. Puneet Rai, SSC.
versus
M/S TCK ADVISERS PVT. LTD. .....Respondent
Through: None.
CORAM:
HON'BLE MR. JUSTICE DINESH MEHTA
HON'BLE MR. JUSTICE VINOD KUMAR
22.01.2026 O R D E R 1. 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. 2. In view of the aforesaid, the appeal along with the pending applications, if any, is dismissed.
DINESH MEHTA, J.
VINOD KUMAR, J. JANUARY 22, 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 24/01/2026 at 12:45:33
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