JOINT COMMISSIONER OF INCOME TAX (OSD), CORPORATE CIRCLE-1, COIMBATORE, COIMBATORE vs. PRANAR OILS AND CHEMICALS INDIA PRIVATE LIMITED, COIMBATORE

ITA 476/CHNY/2026Status: DisposedITAT Chennai05 November 20263 pages

In favour of the assessee: the Revenue's appeal was dismissed. From the AI summary of this appeal.

AI SummaryDismissed

What did the Tribunal hold?

The Tribunal held that the appeal filed by the Revenue is not maintainable. The assessee's AR submitted that the tax effect involved in the appeal, computed at the normal effective tax rate of 45.02% on the disputed addition of Rs.1,12,75,387/-, works out to Rs.49,89,207/-. This amount is below the monetary limit of Rs.60,00,000/- prescribed by the CBDT under Circular No. 09/2024 dated 17.09.2024 for filing appeals by the Revenue. The Tribunal noted that the Revenue did not dispute this calculation or claim any exceptions under relevant CBDT circulars. Consequently, the Tribunal found that the appeal was covered by CBDT Circular No. 09/2024 and, in the absence of any applicable exceptions, dismissed the appeal solely on the ground of maintainability. No decision was made on the merits of the grounds raised by the Revenue.

What were the facts?

The Revenue is in appeal against the order of the Commissioner of Income Tax (Appeals) [CIT(A)] dated 14.11.2025 for Assessment Year 2019-20. The CIT(A) had deleted an addition of Rs.1,12,75,387/- made by the Assessing Officer (AO) during remand proceedings. The Revenue's grounds of appeal primarily challenge the CIT(A)'s acceptance of additional grounds, additional evidence, and claims related to payments for imports and custom duty, arguing these were accepted without proper verification by the AO. The assessee is Pranar Oils and Chemicals India Private Limited, and the appellant is the Joint Commissioner of Income Tax.

What were the issues?

1. Whether the appeal filed by the Revenue is maintainable before the Tribunal, considering the tax effect involved in the dispute in light of CBDT Circular No. 09/2024 dated 17.09.2024? Assessee's Contention: The learned Authorized Representative (AR) for the assessee argued that the tax effect of the disputed addition, when computed at the normal effective tax rate of 45.02%, amounts to Rs.49,89,207/-. This figure is below the prescribed monetary limit of Rs.60,00,000/- for filing appeals by the Revenue before the Tribunal as per CBDT Circular No. 09/2024. Therefore, the appeal is not maintainable. Revenue's Contention: The Revenue did not dispute the assessee's calculation of the tax effect or that the case did not fall within any exceptions specified under relevant CBDT Circulars.

Which sections of the Income-tax Act were involved?

None explicitly mentioned as the decision was based on CBDT circulars regarding monetary limits.

AI-generated summary — verify with the full judgment below

Income Tax Appellate Tribunal, ‘C’ BENCH, CHENNAI

Before: SHRI ABY T VARKEY & SHRI S. R. RAGHUNATHA

For Appellant: Mr. J. Saravanan, Advocate

For Respondent: Mr. Beesam Narasing Rao, JCIT

Hearing: 24.09.2026Pronounced: 05.11.2026

आदेश /O R D E R

PER S. R. RAGHUNATHA, AM :

The appeal by the Revenue is directed against the order dated 14.11.2025 of the learned Commissioner of Income Tax (Appeals), National Faceless Appeal Centre (NFAC), Delhi (hereinafter referred to as “ld.CIT(A)”), for the Assessment Year (A.Y.) 2019-20. 2. The revenue has raised the following grounds of appeal:

The order of ld.CIT(A) is against the law, facts and circumtances of the case.

:-2-: ITA. No:476/Chny/2026. 2. The ld.CIT(A) has reed in allowing the additional grounds raised by the assessee company which were not claimed during original assessment or in the letter dt. 22.05.2025 i.e., before called for remand report. 3. The ld.CIT(A) has erred by accepting the additional evidences which are clearly an after thought after receipt of remand report from the AO. 4. The ld.CIT(A) has erred by accepting the claim of the assessee that Rs.51,90,323/- was paid during the period from 03.04.2019 to 24.04.2019, without giving an opportunity to the Assessing Officer to verify whether the payments have nexus with the imports made by the assessee company or not. 5. The ld.CIT(A) has erred in giving relief to the tune of Rs.59,32,842/- the amount no where matches with any value of the four bills claimed by the assessee towards goods imported vide letter dated 22.05.2025. 6. The ld.CIT(A) has erred in giving relief to the tune of Rs.53,42,545/- towards custom duty payment by accepting the payment through Director’s account, without questing the necessity and nexus between the payment from Director’s bank account and the imports made by the assessee company, the said bank statement was also not provided to the AO while called for remand report. 7. The above grounds and additional grounds of appeal may be adduced at the time of hearing to set aside the order passed by the ld.CIT(A). 3. The brief facts of the case, as emanating from the records and the grounds of appeal raised by the Revenue, are that the grievance of the Revenue is against the action of the Learned Commissioner of Income Tax (Appeals) [hereinafter referred to as the “ld. CIT(A)”] in deleting the addition of Rs.1,12,75,387/- made by the AO during the remand proceedings.

At the outset, the ld. AR submitted that the tax effect involved in the present appeal is below the prescribed monetary limit of Rs.60,00,000/- for filing appeals before the Tribunal by the Revenue. In this regard, it was submitted that, although the AO had reported the tax effect in Form No. 36 at Rs.87,94,802/-, computed by applying the maximum tax rate of 60% plus applicable surcharge, the actual tax effect on the disputed addition of Rs.1,12,75,387/-, computed at the normal effective tax rate of 45.02%, works out to only Rs.49,89,207/-. The aforesaid computation is stated to be in accordance with the Order Giving Effect (OGE) to the order of the ld.CIT(A), dated 02.12.2025. Accordingly, the ld.AR contended that the tax effect involved in the appeal is below the monetary threshold of Rs.60,00,000/- prescribed by

:-3-: ITA. No:476/Chny/2026. the Central Board of Direct Taxes (CBDT) under Circular No.09/2024 dated 17.09.2024 and, therefore, the appeal filed by the Revenue is not maintainable.

We have considered the submissions of the ld.AR and perused the material available on record. It is not disputed by the Revenue that the present case does not fall within any of the exceptions specified under the relevant CBDT Circulars, including Circular No.05/2024 dated 15.03.2024. Having regard to the tax effect of Rs.49,89,207/- involved in the disputed addition, which is below the prescribed monetary limit of Rs.60,00,000/-, we find that the present appeal is covered by CBDT Circular No. 09/2024 dated 17.09.2024. In the absence of any applicable exception to the said circular, the appeal filed by the Revenue is not maintainable and is, accordingly, dismissed on this ground alone.

In the result, appeal filed by the Revenue is dismissed.

Order pronounced in the open court on 05th November, 2026 at Chennai. Sd/- Sd/- (एबी ट� वक� ) (एस. आर. रघुनाथा) (ABY T VARKEY) (S. R. RAGHUNATHA) �या�यक सद�य/Judicial Member लेखासद�य/Accountant Member चे�ई/Chennai, िदनांक/Dated, the 05th November, 2026 Digitally signed by EJTADA DURGA EJTADA DURGA NARESH Devadas NARESH Date: 2026.11.13 11:48:09 +05'30' आदेश क� ��त�ल�प अ�े�षत/Copy to: 1. अपीलाथ'/Appellant 2. ()यथ'/Respondent 3.आयकर आयुCत/CIT– Chennai/Coimbatore/Madurai/Salem 4. Nवभागीय (�त�न�ध/DR 5. गाड% फाईल/GF

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