INCOME TAX OFFICER, PATIALA vs. TUSHAR BANSAL, PATIALA

ITA 1588/CHANDI/2025Status: DisposedITAT Chandigarh24 February 2026AY 2019-20Bench: SHRI RAJPAL YADAV (Vice President), SHRI MANOJ KUMAR AGGARWAL (Accountant Member)4 pages
AI SummaryDismissed

What did the Tribunal hold?

The Tribunal observed that the tax effects for the quantum appeal (Rs. 3,77,743/-) and penalty orders (Rs. 37,260/-, Rs. 10,000/-) were all below the Rs. 60 lacs monetary limit prescribed by the CBDT Circular, and none of the exceptional clauses applied. Accordingly, the Tribunal dismissed all three appeals as not maintainable. However, it granted the Revenue liberty to revive the appeals via a Miscellaneous Application if re-verification showed a higher tax effect or if an exceptional clause applied, within the time limit stipulated under Section 254(2) of the Act.

What were the facts?

The Revenue filed three appeals against separate orders of the CIT(A) for AY 2019-20. One appeal arose from assessment proceedings under sections 147/144, while the other two were from penalty proceedings under sections 271AAC(1) and 272A(I)(d) of the Income Tax Act. The assessee contended that all appeals were not maintainable because the tax effect in each appeal was below the Rs. 60 lacs monetary limit specified in CBDT Circular No. 09/2024 dated 17.09.2024.

What were the issues?

Whether appeals filed by the Revenue are maintainable if the tax effect is below the monetary limit prescribed by CBDT Circulars, and the scope for revival of such dismissed appeals under specific circumstances.

Which sections of the Income-tax Act were involved?

Section 147,Section 144,Section 271AAC(1),Section 272A(I)(d),Section 254(2)

AI-generated summary — verify with the full judgment below

Income Tax Appellate Tribunal, DIVISION BENCH, ‘A’ CHANDIGARH

Before: SHRI RAJPAL YADAV & SHRI MANOJ KUMAR AGGARWAL

For Appellant: Shri Ashwani Kumar, CA
For Respondent: Dr. Ranjit Kaur, Addl. CIT Sr.DR
Hearing: 19.02.2026Pronounced: 24.02.2026

PER RAJPAL YADAV, VP

The present three appeals are directed at the instance of the Revenue against the separate orders of ld. Commissioner of Income Tax (Appeals) [in short ‘the CIT (A)’] dated 10.11.2025 passed in assessment years 2019-20. 2. A perusal of the record would indicate that ITA No. 1552/CHD/2025 emerges out from the proceedings u/s 147

ITA No.1552, 1565 & 1588/CHD/2025 A.Y.2019-20 2

read with Section 144 of the Act. The AO has passed the assessment order on 06.01.2025 whereas ITA No. 1565/CHD/2025 emerges out of penalty proceedings u/s 271AAC(1) of the Incom

The order continues below.

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