THE PR. COMMISSIONER OF INCOME TAX-9 vs. BUREAU VERITAS CERTIFICATION (I) PVT. LTD.

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ITXA/3320/2018HC BombayHCBM02018834201823 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 Tribunal disposed of the Income Tax Appeal on the ground that the disputed claim of Rs. 7,00,745/- is below the threshold of Rs. 2 Crores as stipulated in the CBDT Circular dated 17th September 2024. Consequently, no order as to costs was made. The Tribunal granted liberty to the parties to revive the appeal in the event that the tax effect involved was not within the parameters of the said Circular. The ratio decidendi is that appeals with a tax effect below the threshold specified by the CBDT Circular are to be disposed of on that basis, without delving into the merits of the case, unless liberty is granted to revive.

What were the facts?

The appeal was filed by the Principal Commissioner of Income Tax (Appellant) against Bureau Veritas Certification (I) Pvt. Ltd. (Respondent). The disputed claim in the appeal was valued at Rs. 7,00,745/-. The judgment is dated 23rd December 2025. The High Court of Judicature at Bombay was hearing the Income Tax Appeal No. 3320 of 2018. The procedural history leading to this hearing is not detailed, other than the appeal being presented before the court.

What were the issues?

1. Whether the Income Tax Appeal is maintainable given its tax effect in light of CBDT Circular dated 17th September 2024. The Appellant, represented by Mr. Suresh Kumar, likely sought to have the appeal heard on its merits. The Respondent, represented by Mr. V.S. Hadade, would have argued in support of the court's decision based on the tax effect. The core of the dispute revolves around the applicability and interpretation of the CBDT Circular which sets monetary limits for filing appeals. The judgment does not explicitly state the arguments made by each side beyond their representation, but the decision hinges on the tax effect and the circular.

AI-generated summary — verify with the full judgment below

Cause title — parties, addresses and appearances

Pr. Comm. of Income Tax Vs. Bureau Veritas Cert. 8.ITXA/3320/2018 IN THE HIGH COURT OF JUDICATURE AT BOMBAY ORDINARY ORIGINAL CIVIL JURISDICTION INCOME TAX APPEAL NO. 3320 OF 2018 The Pr. Commissioner of Income Tax – 9. … Appellant V/s. Bureau Veritas Certification (I) Pvt. Ltd., … Respondent _______________________________________ Mr. Suresh Kumar for Appellant. Mr. V.S. Hadade for Respondent. _______________________________________ CORAM : R.I. CHAGLA AND FARHAN P. DUBASH, JJ. DATE : 23rd DECEMBER 2025

ORDER :

We have perused the disputed claim in the above Income Tax Appeal which is valued at Rs. 7,00,745/- and thus below the tax effect of Rs. 2 Crores as per the CBDT Circular dated 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 the Income Tax Appeal on that ground. There shall be no order as to costs. ------------------------------------- 8.ITXA/3320/2018

In the event the tax effect as involved is not within the parameters of the Circular dated 17th September 2024, liberty to revive this Appeal. [FARHAN P. DUBASH, J.] [R.I. CHAGLA, J.] Ajay Jadhav 8.ITXA/3320/2018 ------------------------------------- Order dated 23rd December 2025 JYOTI PRAKASH PAWAR PRAKASH PAWAR Date: 2025.12.23 19:22:17 +0530

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