DY. COMMISSIONER OF INCOME TAX (INTERNATIONAL TAXATION) – 3(1)(1), MUMBAI, MUMBAI vs. JEFFERIES SINGAPORE LIMITED , SINGAPORE
In favour of the assessee: the Revenue's appeal was dismissed. From the AI summary of this appeal.
What did the Tribunal hold?
The Tribunal noted that the tax effect on the disputed issues was less than Rs. 60,00,000/-, which is the monetary limit for filing appeals as per CBDT Circular No. 09/2024. Therefore, the appeals were dismissed in limine.
What were the facts?
The Revenue filed appeals against the assessment orders for A.Y. 2016-17 and 2018-19. The disputed amounts were Rs. 4,53,339/- and Rs. 11,58,353/- respectively.
What were the issues?
Whether appeals filed by the Revenue should be dismissed on grounds of low tax effect, considering the CBDT's monetary limits for filing appeals before the Tribunal.
Which sections of the Income-tax Act were involved?
AI-generated summary — verify with the full judgment below
Income Tax Appellate Tribunal, ‘I’ BENCH
आदेश / O R D E R PER BENCH: The aforesaid appeals have been filed by the Revenue for the quantum of assessment passed u/s.143(3) / 144C for the A.Y.2016-17 and 2018-19 against final assessment order dated 31/01/2020 and 20/03/2024 respectively.
At the outset, it has been pointed out that the dispute raised in the Revenue’s appeal in A.Y.2016-17 is only with & 3043/Mum/2024 M/s. Jefferies Singapore Limited regard to Rs. 4,53,339/- and since the issue pertains to FTS where the rate of tax under the DTAA is 10%, therefore, the tax effect is only Rs.45,334/-. Similarly, in A.Y.2018-19 the disputed amount in the appeal filed by the Revenue is Rs.11,58,353/- and the tax effect is Rs.1,15,836/- .
Both the parties have agreed that the tax effect on the disputed issue is less than Rs.60,00,000/- which is a monetary limit prescribed by the CBDT vide Circular No.09/2024 dated 17/09/2024 for filing of the appeal, wherein the limit prescribed for filing of appeal by the department before the Tribunal has been capped at Rs.60,00,000/-. Admittedly here in this case the tax effect is less than Rs.60,00,000/- and accordingly, the appeals of the Revenue are dismissed in limine on account of low tax effect.
In the result, both the appeals of the Revenue are dismissed.
Order pronounced on 2nd January, 2025.
More judgments on Section 144C
- Mishoo Sahay, Bangalore vs ACIT, Circle 2(1), It, KolkataITTPA 19/KOL/2026[2013-2014]Status: Disposed15 Oct 2026AY 2013-2014
- Anshu Sahay, Bangalore vs ACIT, Circle 2(1), It, KolkataITTPA 18/KOL/2026[2016-2017]Status: Disposed15 Oct 2026AY 2016-2017
- Anshu Sahay, Bangalore vs ACIT, Circle 2(1), It, KolkataITTPA 17/KOL/2026[2015-2016]Status: Disposed15 Oct 2026AY 2015-2016
- Anshu Sahay, Bangalore vs ACIT, Circle 2(1), It, KolkataITTPA 16/KOL/2026[2014-2015]Status: Disposed15 Oct 2026AY 2014-2015
- Anshu Sahay, Bangalore vs ACIT, Circle 2(1), It, KolkataITTPA 15/KOL/2026[2013-2014]Status: Disposed15 Oct 2026AY 2013-2014
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