ITO CORPORATE WARD 2, COIMBATORE vs. M/S METALCITY CONSTURCTIONS PVT LTD, COIMBATORE
In favour of the assessee: the Revenue's appeal was dismissed. From the AI summary of this appeal.
What did the Tribunal hold?
The Income Tax Appellate Tribunal (ITAT) dismissed the Revenue's appeal as not maintainable/withdrawn. This decision was based on CBDT Circular No.09 of 2024, which increased the monetary limit for Revenue appeals to ₹60 lakhs, and the tax effect in the instant case being less than this revised limit.
What were the facts?
The Revenue filed an appeal against the order of the Ld.CIT(A) for the Assessment Year 2014-15. It was observed that the tax effect of the relief granted by the Ld.CIT(A) was below ₹60 lakhs, which is the revised monetary limit for filing appeals by the Revenue before the ITAT.
What were the issues?
Whether the Revenue's appeal is maintainable before the ITAT when the tax effect is below the monetary limit prescribed by CBDT Circular No.09 of 2024.
Which sections of the Income-tax Act were involved?
AI-generated summary — verify with the full judgment below
Income Tax Appellate Tribunal, ‘C’ BENCH: CHENNAI
Before: SHRI ABY T. VARKEY & SHRI AMITABH SHUKLA
आदेश / O R D E R
PER ABY T. VARKEY, JM:
This is an appeal preferred by the Revenue against the order of the Learned Commissioner of Income Tax (Appeals), (hereinafter in short ‘the Ld.CIT(A)’), NFAC, Delhi, dated 27.03.2025 for the Assessment Year (hereinafter in short ‘AY’) 2014-15.
At the outset, we notice that the tax effect of the relief granted by the Ld.CIT(A) is below ₹60 lakhs and as per Circular No.09 of 2024 dated 17.09.2024 issued by the Central Board of Direct Taxes (hereinafter in short ‘CBDT’), Department of Revenue, Ministry of Finance, Government of India, the CBDT has revised the monetary limit for Revenue filing appeals before the ITAT from the existing limit of ₹50 lakhs to ₹60 lakhs.
The Ld.DR fairly conceded that per-se this appeal is covered by the aforesaid Circular issued by the CBDT. However, he submitted that in case, this appeal falls in the exceptional clause, the decision may be recalled. This plea of the Revenue will be considered on its merits when occasion arises and we don’t express any view on such plea of Ld.DR.
Having stated so, and having gone through the order of the Ld.CIT(A) and the grounds of appeals, we find per-se that the tax effect in the captioned appeal is less than ₹60 lakhs. Accordingly, we dismiss the aforesaid appeal filed by the Revenue as not maintainable/withdrawn on the strength of the CBDT Circular (supra).
In the result, the appeal filed by the Revenue stands dismissed.
Order pronounced on the 22nd day of August, 2025, in Chennai.
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