THE PR. COMMISSIONER OF INCOME TAX -CENTRAL -1 vs. OM PRAKASH ARORA
What did the High Court hold?
The High Court of Delhi held that the appeal filed by the Revenue was dismissed. The Court's reasoning was based on the submission made by the assessee's senior counsel regarding the tax effect. The Court, after a prima facie examination, was of the view that the tax effect was below Rs. 2 crores. The Revenue's counsel was unable to counter this assertion or satisfy the Court on the tax effect. Therefore, in light of the low tax effect and the inability of the Revenue to demonstrate otherwise, the appeal was dismissed. The ratio decidendi is that appeals with a tax effect below the prescribed monetary limits, as per CBDT circulars, are liable to be dismissed, especially when the Revenue cannot justify the tax effect. The operative direction was the dismissal of the appeal.
What were the facts?
This case involves an appeal filed by the Principal Commissioner of Income Tax - Central -1 (the Revenue) against the respondent-assessee, Om Prakash Arora. The appeal is before the High Court of Delhi. The procedural history that matters is the submission by the assessee's counsel that the tax effect in the appeal falls 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 Court, upon prima facie examination, agreed that the tax effect appeared to be below Rs. 2 crores. The Revenue's counsel was unable to satisfy the Court regarding the tax effect.
What were the issues?
1. Whether the appeal filed by the Revenue is maintainable in light of the tax effect being below the monetary limits prescribed by CBDT Circulars No.5/2024 and 9/2024? (Question of law) Assessee's Contentions: The 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 be entertained. Revenue's Contentions: The Revenue's counsel could not satisfy the Court regarding the tax effect involved in the present appeal.
AI-generated summary — verify with the full judgment below
$~2 * IN THE HIGH COURT OF DELHI AT NEW DELHI + ITA 56/2026
THE PR. COMMISSIONER OF INCOME TAX -CENTRAL -1 .....Appellant Through: Mr Ruchir bhatia, SSC & Mr. Anant Mann, JSC.
versus
OM PRAKASH ARORA
.....Respondent Through: Mr. Ajay Vohra, Sr. Advocate with Mr. Aditya Vohra, Advocate.
CORAM:
HON'BLE MR. JUSTICE DINESH MEHTA
HON'BLE MR. JUSTICE VINOD KUMAR
O R D E R %
12.03.2026 1. Mr. Ajay Vohra, learned senior counsel appearing for the respondent- assessee submits 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. On prima-facie examination of the material, we are also of the view that tax-effect is below Rs. 2 crores. 3. Mr. Anant Mann, learned Junior Standing Counsel, could not satisfy the Court regarding tax-effect involved in the present appeal. 4. In view of the aforesaid, the appeal stands dismissed.
DINESH MEHTA, J.
VINOD KUMAR, J. MARCH 12, 2026/nk
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 16/03/2026 at 15:54:02
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