PR. COMMISSIONER OF INCOME TAX-6, NEW DELHI vs. MICRO SPACEMATRIX SOLUTION PVT. LTD.

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ITA/790/2016HC DelhiDLHC01285144201630 January 2025Bench: HON'BLE MR. JUSTICE YASHWANT VARMA,HON'BLE MR. JUSTICE HARISH VAIDYANATHAN SHANKAR1 pages

AI SummaryDismissed

What did the High Court hold?

The High Court held that the tax effect in this appeal falls below INR 2 Crores. Consequently, in light of Circular No. 9/2024 dated 17 September 2024, the appeal is not liable to be continued. The Court dismissed the appeal on the ground of low tax effect. The proposed questions of law are explicitly kept open to be urged and addressed in an appropriate future case. No decision was made on the merits of the substantive tax dispute.

What were the facts?

This appeal concerns the Principal Commissioner of Income Tax-6, New Delhi (the Revenue) and Micro Spacematrix Solution Pvt. Ltd. (the Assessee). The specific assessment year(s) and the original order or action under challenge are not detailed in this judgment. The procedural history is limited to the present appeal before the High Court. The core of the matter, as presented in the judgment, revolves around the tax effect of the dispute, which is stated to be below INR 2 Crores.

What were the issues?

The High Court was not required to decide substantive questions of law or fact. The primary issue that arose for consideration was whether the appeal should be dismissed due to a low tax effect, in light of a relevant circular. The Revenue, represented by Mr. Puneet Rai, SSC, did not present arguments on the merits of the case. The Assessee, represented by Mr. Somil Agarwal and Mr. Dushyant Agarwal, Advs., also did not argue the substantive issues. The judgment focuses solely on the applicability of the circular regarding low tax effect.

AI-generated summary — verify with the full judgment below

$~351 * IN THE HIGH COURT OF DELHI AT NEW DELHI + ITA 790/2016

PR. COMMISSIONER OF INCOME TAX-6, NEW DELHI .....Appellant Through: Mr. Puneet Rai, SSC with Mr. Ashvini Kumar, Mr. Rishabh Navsia, JSC

versus

MICRO SPACEMATRIX SOLUTION PVT. LTD.

.....Respondent Through: Mr. Somil Agarwal & Mr. Dushyant Agarwal, Advs.

CORAM:

HON'BLE MR. JUSTICE YASHWANT VARMA HON'BLE MR. JUSTICE HARISH VAIDYANATHAN SHANKAR

O R D E R %

30.01.2025

Undisputedly, the tax effect which forms the subject matter of this appeal falls below INR 2 Crores and would thus not be liable to be continued in light of the provisions made in Circular No. 9/2024 dated 17 September 2024. 2. The appeal is, consequently, dismissed on the ground of low tax effect. The proposed questions of law are kept open to be urged and addressed in an appropriate case.

YASHWANT VARMA, J.

HARISH VAIDYANATHAN SHANKAR, J. JANUARY 30, 2025/v 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 06/02/2025 at 14:47:34

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