THE COMMISSIONER OF INCOME TAX-I vs. DR REDDYS LABORATORIES LTD.,

ITTA/193/2015HC TelanganaHBHC01072800201517 September 2025Bench: P.SAM KOSHY,SUDDALA CHALAPATHI RAO4 pages

AI SummaryDismissed

What did the High Court hold?

The High Court dismissed the appeal filed by the Revenue. The dismissal was based on CBDT Circular No. 9 of 2024, dated 17.09.2024, which enhances the monetary limits for filing appeals by the Income Tax Department to reduce litigation. The Court found that the tax effect in the instant appeal was well below the prescribed monetary limit of Rs. 2 crore for appeals before the High Court. However, the Court also provided a conditional relief, stating that if the appeal falls within the exceptions of Circular No. 5 of 2024, the Revenue would be at liberty to seek revival of the appeal. No specific decision was made on the merits of the original ITAT order.

What were the facts?

This case involves an appeal filed by the Revenue (Commissioner of Income Tax-I, Hyderabad) against an order dated 25-07-2013 passed by the Income Tax Appellate Tribunal (ITAT), Hyderabad Bench-B. The ITAT's order was in relation to Income Tax Appeal No. 417/Hyd/2006 for the Assessment Year 2001-2002. The original assessment order was passed by the Assistant Commissioner of Income Tax, Circle 1(2), Hyderabad, and a further order was passed by the Commissioner of Income Tax, Hyderabad-I. The respondent in this appeal is M/s. Dr Reddy's Laboratories Ltd. The appeal is preferred under Section 260A of the Income Tax Act, 1961.

What were the issues?

1. Whether the appeal filed by the Revenue is maintainable in light of the monetary limits prescribed by the Central Board of Direct Taxes (CBDT) for filing appeals. The Revenue, as the appellant, argues that the appeal should be considered based on its merits. The Respondent (assessee) does not appear to have made any specific arguments recorded in this excerpt. The core issue revolves around the applicability of CBDT Circular No. 9 of 2024 (amending Circular No. 5 of 2024) which sets a monetary limit of Rs. 2 crore for filing appeals before the High Court. The judgment notes that the tax effect in the instant appeal is well below this limit.

Which sections of the Income-tax Act were involved?

Section 260A

AI-generated summary — verify with the full judgment below

I I i [ 348s 1 IN THE HIGH COURT FOR THE STATE OF TELANGANA AT HYDERABAD WEDNESDAY, THE SEVENTEENTH DAY OF SEPTEMBER TWO THOUSAND AND TWENTY FIVE PRESENT THE HONOURABLE SRI JUSTICE P.SAM KOSHY AND THE HONOURABLE SRI JUSTICE SUDDALA CHALAPATHI RAO INCOME TAX TRIBUNAL APPEAL NO: 193 0F 2015 'Appealfiledundersection260_AofthelncomeTaxAct.l96lagainstthe order dated 25-07-2013 in lTA.No. 417tHydt2\06 on the file of the lncome Tax Appellate Tribunal, Hyderabad, Bench-B, Hyderabad for the Assessment Year 2OO1-20O2 preferred against the order dated 06-04-2006 in GIR No. D-96/AC 1(2)l2OO1-02 on the file of the Assistant commissioner of lncome Tax, Circle 1(2), Hyderabad preferred against the order dated 3'1-3-2006 in PAN/GIR No' AAACD7999Q on the file of the commissioner of lncome Tax, Hyderabad-|, Hyderabad. Between: The Commissioner Of lncome Tax-|, Hyderabad ...APPELLANT AND M/s. Dr Reddy's Laboratories Ltd.,7-1-27 ' Ameerpet, Hyderabad ...RESPONDENT Counsel for the Appellant: Ms. J. Sunitha (Senior Standing Counsel for lncome Tax Dept') Counsel for the Respondent: Sri Venkatram Reddy Mantur The Court detivered the following: JUDGMENT 'a\

THE H NO BLE RI STI P.SA K AND HY T EH N RA LES JU ICE DA CHA P HI o INCOMI: TAX TRIBUNAL APPEAL No.193 of 2015 JUDGMENT: (pet the Hon'bte Sri lustice p.sam Koshy) Heard Ms. i.Sunitha, learned Senior Standing Counsel for Income Tax Department appearing on behalf of the appellant, and [4r. Venkatram Reddy Mantur, learred counsel for the respondent. 2. The instant appear under section 2604 of the Income Tax Act, 1961, has been pr:ferred by the Revenue as the appellant against the order dated 25.07.7073, passed by the Income Tax Appellate Tribunal, Hyderabad Bench '8,, Hyderabad, in I.T.A.No.4 t7/HVd/2006 for the Assessment Yea r 2(l01-02. 3' centrar Boerrri of Direct raxes (CBDT) has issued circurar r,Jo.g of 2024 dated 17.09.n024, amending the previous circurar No.5 0f 2024 dated 15.03.202'+, r:ty further enhancing the monetary rimits for firing appeals by the Inc. rre Tax Department before the Income Tax Appeilate Tribunars, High courts and Supreme court as a measure for reducing litigation. In paragraph 2 of the said circurar, we Find that the monetary limit fixed for firinq an appeal before the High court is Rs.2 crore.

Page 2 ol 2 4. In the instant appeal, tax effect is well below the monetary limit. 5. Therefore, the appeal filed by the Revenue is dismissed in terms of the aforesaid Circular No.9 of 2024, dated 77.O9.2024. However, if the appeal comes within the exception of Circular No.5 of 2024, it would be open to the Revenue to seek revival of the appeal. 6. As a sequel, miscellaneous petitions pending if any, shall stand closed. However, there shall be no order as to costs. SD/- A.V.S PRASAD EPUTY REGISTRAR ,TRUE COPY// SECTION OFFICER To, W 1. The lncome Tax Appellate Tribunal, Hyderabad, Bench-B, Hyderabad 2. The Assistant Commissioner of lncome Tax, Circle '1(2), Hyderabad 3. The Commissioner of lncome Tax, Hyderabad-1, Hyderabad' 4. One CC to Ms. J. Sunitha (Senior Standing Counsel for lncome Tax Department) [OPUC] 5. One CC to Sri Venkatram Reddy Mantur, Advocate [OPUC] 6. Two CD CoPies VH/?SL

/ HIGH COURT DATED: 1710912025 JUDGMENT lTTA.No.193 of 2015 DISMISSING ITTA /=::-=='--:::' .-.: .,\r. -t, :.,1" ' - - ^' 0I EtI 2325 --:-- ri -\ /\ N

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