THE PR. COMMISSIONER OF INCOME TAX (CENTRAL), PUNE vs. ANKIT ENTERPRISES
What did the High Court hold?
The Bombay High Court disposed of the Income Tax Appeal on the ground that the tax effect involved in the appeal, which was Rs. 29,96,297/-, was below the threshold of Rs. 2 Crores as per the CBDT Circular dated September 17, 2024. Consequently, the appeal was disposed of on this basis, and no order as to costs was made. The Court granted liberty to the appellant to revive the appeal if the tax effect was found to be outside the parameters of the said circular. The substantive issues of the appeal were not adjudicated upon.
What were the facts?
The appeal was filed by the Principal Commissioner of Income Tax (Central), Pune, against Ankit Enterprises. The disputed claim in the appeal amounted to Rs. 29,96,297/-. The appeal was filed before the Bombay High Court. The assessment year(s) are not specified in the judgment. The procedural history involves the filing of the Income Tax Appeal by the revenue. The judgment is dated December 4, 2025.
What were the issues?
1. Whether the Income Tax Appeal is maintainable in light of the tax effect being below the threshold stipulated by the CBDT Circular dated September 17, 2024? (Question of law) Assessee's Contention: The assessee did not explicitly argue any points as the appeal was disposed of on the ground of tax effect. The judgment does not record any specific arguments made by the assessee. Revenue's Contention: The revenue, as the appellant, would have presented the case on its merits. However, the judgment indicates the appeal was disposed of based on the tax effect criteria of the CBDT Circular, implying the revenue's arguments on the substantive issues were not considered due to this procedural ground. The judgment does not record specific arguments made by the revenue on the merits of the case.
AI-generated summary — verify with the full judgment below
Cause title — parties, addresses and appearances
ORDER :
We have perused the disputed claim in the above Income Tax Appeal which is valued at Rs.29,96,297/- and thus below the tax effect of Rs.2 Crores as per the CBDT Circular 17th September, 2024. ------------------------------------------------- Order dated December 4, 2025 JITENDRA SHANKAR NIJASURE JITENDRA SHANKAR NIJASURE Date: 2025.12.05 15:40:15 +0530
26-itxa-1165-2016.doc Pr. Comm. Of Income Tax v. Ankit Enterprises
In view of the tax effect in 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.
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.] 26-itxa-1165-2016.doc jsn. ------------------------------------------------- Order dated December 4, 2025
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