What did the Tribunal hold?

The Tribunal noted that the CBDT circular regarding the minimum tax effect was applicable retrospectively to pending appeals. Therefore, the Revenue's appeal was rejected on this specific ground.

The Revenue filed an appeal against the CIT(A)/NFAC's order for Assessment Year 2017-18. The appeal involved a tax effect of Rs.23,21,893/-, which was less than the minimum prescribed tax effect of Rs.60 lakhs under CBDT Circular No. 9/2024.

What were the issues?

Whether the Revenue's appeal, with a tax effect below the threshold specified in CBDT Circular No. 9/2024, is maintainable given its retrospective applicability to pending appeals.

Raman Gupta vs DCIT | s.143(3) | ITAT Delhi 2025

Income Tax Appellate Tribunal, DELHI BENCH ‘SMC’, NEW DELHI

Before: Sh. Satbeer Singh Godara

Hearing: 23.07.2025Pronounced: 23.07.2025

ORDER This Revenue’s appeal for Assessment Year 2017-18, arises against the CIT(A)/NFAC, Delhi’s DIN & order No. ITBA/NFAC/S/250/2024-25/1074757252(1) dated 20.03.2025, in proceedings u/s 143(3) of the Income Tax Act, 1961 (in short “the Act”).

Heard both the parties at length. Case file perused.

It emerges at the outset that the Revenue's instant appeal involves tax effect of Rs.23,21,893/- which is less than the minimum tax effect prescribed of Rs.60 lakhs in the CBDT latest Circular No. 9/2024, dated 17.09.2024.

Learned Departmental Representative is indeed very fair in not disputing the fact that the CBDT's foregoing tax effect Rohto Pharma (India) Pvt. Ltd. circular has been made applicable with retrospective effect on all pending appeals as well. I thus reject the Revenue's instant appeal for this precise reason subject to all just exceptions.

RAMAN GUPTA,DELHI vs. DCIT CENTRAL CIRCLE-17, DELHI

What did the Tribunal hold?

What were the facts?

What were the issues?

Which sections of the Income-tax Act were involved?

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