PRINCIPAL COMMISSIONER OF INCOME TAX, RANCHI, THROUGH AMITABH KUMAR SINHA vs. ARVINDER GANDHI
What did the High Court hold?
The High Court rejected the Revenue's contention regarding the applicability of Exception Clause 3.1(f) of CBDT Circular No. 5 of 2024. The Court relied on its previous reasoning in an identical matter, Tax Appeal No. 10 of 2024, where it had already rejected a similar argument. Consequently, since the tax effect was less than Rs. 2 Crores and the exception clause did not apply, the appeal was disposed of on the grounds of low tax effect. The questions of law raised in the appeal were left open. The pending interlocutory application was also disposed of.
What were the facts?
The appeal was filed by the Principal Commissioner of Income Tax, Ranchi (the Revenue) against the respondent, Arvinder Gandhi. The appeal concerns a tax effect less than Rs. 2 Crores. The Revenue sought to entertain the appeal by invoking an exception clause (Clause 3.1(f)) of CBDT Circular No. 5 of 2024. The assessee argued that the appeal should not be entertained due to the low tax effect as per the said circular. The High Court had previously dealt with an identical matter in Tax Appeal No. 10 of 2024, where it rejected a similar contention by the appellant regarding the applicability of the exception clause.
What were the issues?
1. Whether the appeal filed by the Revenue should be entertained, given that the tax effect is less than Rs. 2 Crores, in light of CBDT Circular No. 5 of 2024? Assessee's contention: The appeal ought not to be entertained as the tax effect is below the threshold stipulated in CBDT Circular No. 5 of 2024, and no exception applies. Revenue's contention: The appeal should be entertained as Exception Clause 3.1(f) of CBDT Circular No. 5 of 2024 is applicable.
Which sections of the Income-tax Act were involved?
Not Specified
AI-generated summary — verify with the full judgment below
Neutral Citation No. 2026:JHHC:30538-DB Page 1 of 2
IN THE HIGH COURT OF JHARKHAND AT RANCHI
T.A. No. 4 of 2026 Principal Commissioner of Income Tax, Ranchi, having his office at Central Revenue Building, 5A Main Road, Ranchi- 834001, P.O. GPO, P.S. Lower Bazar, District- Ranchi, Jharkhand, through Amitabh Kumar Sinha, aged about 56 years, son of Late Ashok Kumar Sinha, having office at Central Revenue Building, 5A Main Road, Ranchi, P.O. GPO, P.S. Lower Bazar, District- Ranchi, Jharkhand Appellant/ Respondent ... Appellant/Respondent
Versus Arvinder Gandhi, PAN: ACEPG2966P, son of not known, having office at Hindustan Infotech, Jain Temple Road, Upper Bazar, Ranchi- 834001, P.O. GPO, P.S. Kotwali, District - Ranchi, Jharkhand. ... Respondent/Appellant
--------- CORAM: HON’BLE THE CHIEF JUSTICE
HON’BLE MR. JUSTICE ARUN KUMAR RAI
--------- For the Appellant: Mr Kumar Vaibhav, Sr. S.C.-ITD
Mr Anurag Vijay, Jr. S.C.-ITD
Ms Saudamini Gupta, Advocate
Mr Durgesh Agarwal, Advocate For the Respondent: Ms Amrita Sinha, Advocate
Ms Pragunee Kashyap, Advocate
--------- 03/Dated: 12.10.2026 Per M. S. Sonak, C.J. 1. Heard Mr Kumar Vaibhav, learned Sr. S.C. for the appellant, and Ms Amrita Sinha who appears with Ms Pragunee Kashyap for respondent. 2. The tax effect in this appeal is less than Rs. 2 Crores. Therefore, Ms Amrita Sinha submits that this appeal may not be entertained given the CBDT Circular No. 5 of 2024 dated 15th March 2024. 3. Mr Kumar Vaibhav however submits that Exception in Clause 3.1(f) of the Circular would apply.
Neutral Citation No. 2026:JHHC:30538-DB Page 2 of 2
In an identical matter, i.e. Tax Appeal No. 10 of 2024 which was disposed of by order dated 24.02.2026, we had considered and rejected the appellant’s contention regarding applicability of the Exception clause. 5. Therefore, by applying the reasoning in our order dated 24.02.2026, we reject the contention about the application of the Exception clause and uphold the objection raised on behalf of the assessee. 6. Since, the tax effect in this matter is less than Rs. 2 Crores and the Exception clause does not apply, we dispose of this appeal on the grounds of low tax effect by leaving open the questions of law raised therein. 7. Pending I.A. does not survive and is disposed of.
(M. S. Sonak, C.J.)
(Arun Kumar Rai, J.) October 12, 2026 N.A.F.R. Manoj/RC/Cp.2 Uploaded on 14.10.2026
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