PR. COMMISSIONER OF INCOME TAX-1 vs. MAHARASHTRA INDUSTRIES AND RE-ROLLING MILLS

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ITXA/3128/2018HC BombayHCBM02030157201811 December 2025Author: HON'BLE SHRI JUSTICE R. I. CHAGLA,HON'BLE SHRI JUSTICE FARHAN PARVEZ DUBASH2 pages
AI SummaryDismissed

What did the High Court hold?

The High Court held that the Income Tax Appeal, with a disputed claim of Rs. 3,39,199/-, falls below the tax effect threshold of Rs. 2 Crores as per the CBDT Circular dated 17th September 2024. Consequently, the Court disposed of the appeal on this specific ground. The reasoning is solely based on the monetary limit set by the CBDT circular. The ratio decidendi is that appeals with a tax effect below the stipulated threshold in the relevant CBDT circular are to be disposed of on that basis. The operative direction is to dispose of the appeal on the ground of tax effect, with no order as to costs. Liberty is granted to revive the appeal if the tax effect is not within the parameters of the circulars dated 17th September 2024.

What were the facts?

The appeal concerns the assessment year(s) not specified in the provided text. The appellant is the Pr. Commissioner of Income Tax-1, and the respondent is M/s Maharashtra Industries & Re-Rolling Mills. The order under challenge is an Income Tax Appeal (ITXA No. 3128 of 2018) filed before the High Court of Judicature at Bombay. The disputed claim is valued at Rs. 3,39,199/-. The appeal was disposed of by the High Court on the ground of tax effect.

What were the issues?

1. Whether the Income Tax Appeal, valued at Rs. 3,39,199/-, is maintainable before the High Court given the monetary limits prescribed by CBDT Circular dated 17th September 2024? (Question of law) The Revenue, represented by Mr. A.K. Saxena, argued that the appeal's tax effect of Rs. 3,39,199/- is below the threshold of Rs. 2 Crores stipulated in the CBDT Circular dated 17th September 2024. Therefore, the appeal should be disposed of on this ground. The Assessee's contentions are not recorded in the provided text.

AI-generated summary — verify with the full judgment below

Cause title — parties, addresses and appearances
The Pr. Commissioner of Income Tax-1 Vs, M/s Maharashtra Industries & Re-Rolling Mills. ITXA No. 3128 of 2018 IN THE HIGH COURT OF JUDICATURE AT BOMBAY ORDINARY ORIGINAL CIVIL JURISDICTION INCOME TAX APPEAL NO. 3128 OF 2018 The Pr. Commissioner of Income Tax-1 … Appellant V/s. M/s Maharashtra Industries & Re-Rolling Mills. … Respondent _______________________________________ Mr. A.K. Saxena for Appellant. _______________________________________ CORAM : R.I. CHAGLA AND FARHAN P. DUBASH, JJ. Date : 11th December 2025

ORDER:

1.

We have perused the disputed claim in the above Income Tax Appeal which is valued at Rs. 3,39,199/- and thus below the tax effect of Rs. 2 Crores as per the CBDT Circular 17th September, 2024. 2. In view of the tax effect, as the present Income Tax Appeal is below Rs. 2 Crores as per said CBDT Circular dated 17th September, 2024, we dispose of Income Tax Appeal on that ground. There shall be no order as to costs.

3.

In the event the tax effect as involved is not within the --------------------------------------------------------------------------------------------------------------------------------------------------------------------------------- Order dated 11th December 2025 JYOTI PRAKASH PAWAR JYOTI PRAKASH PAWAR Date: 2025.12.15 10:29:35 +0530

The Pr. Commissioner of Income Tax-1 Vs, M/s Maharashtra Industries & Re-Rolling Mills.

parameters of the Circulars dated 17th September 2024, liberty to revive this appeal.

( FARHAN P. DUBASH, J. ) ( R.I. CHAGLA J. )

Mandar M. --------------------------------------------------------------------------------------------------------------------------------------------------------------------------------- Order dated 11th December 2025

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