What did the High Court hold?

The High Court dismissed the appeals filed by the Revenue. The dismissal was based on the low tax effect involved, aligning with a previous decision on a connected appeal.

The Revenue filed appeals against the respondent, Ares Diversified, concerning tax effects below the stipulated threshold. The Revenue argued that exceptions under a circular applied, but this contention was previously rejected by a co-ordinate bench.

What were the issues?

Whether the appeals should be dismissed due to low tax effect, despite the Revenue's attempt to invoke exceptions under a circular.

PCIT vs Ares Diversified | Delhi High Court 2025

$~62 & 65 * IN THE HIGH COURT OF DELHI AT NEW DELHI + ITA 67/2025 & CM APPL. 15352-53/2025 THE PRINCIPAL COMMISSIONER OF INCOME TAX - INTERNATIONAL TAXATION -1 .....Appellant Through: Mr Ruchir Bhatia, SSC, Mr Anant Mann, JSC and Mr Abhishek Anand, Advocate. versus ARES DIVERSIFIED .....Respondent Through: None. With + ITA 70/2025 CM APPL. 15401/2025 THE PRINCIPAL COMMISSIONER OF INCOME TAX - INTERNATIONAL TAXATION -1 .....Appellant Through: Mr Ruchir Bhatia, SSC, Mr Anant Mann, JSC and Mr Abhishek Anand, Advocate. versus ARES DIVERSIFIED .....Respondent Through: None. CORAM: HON'BLE MR. JUSTICE VIBHU BAKHRU HON'BLE MR. JUSTICE TEJAS KARIA O R D E R % 17.03.2025 1. Mr. Bhatia, learned counsel appearing on behalf of the Revenue submits that the tax effect involved in the present appeals is below the threshold limit of ₹2,00,00,000/- as stipulated in the circular dated This is a digitally signed order. The authenticity of the order can be re-verified from Delhi High Court Order Portal by scanning the QR code shown above. The Order is downloaded from the DHC Server on 20/03/2025 at 12:37:30

17.09.2024. He states that it is the Revenue’s case that the present appeals would be covered under the exceptions under clause (f) of para 3.1 of the said circular. However, he also fairly points out that said contention was rejected by a co-ordinate Bench of this court in the connected appeal by an order dated 10.03.2025. 2. Since the present appeals [ITA Nos.67/2025 and 70/2025] and ITA No.62/2025 have been filed against a common order, the order passed by this court in ITA No. 62/2025 captioned The Commissioner of Income Tax – International Taxation-1 v. Ares Diversified is equally applicable in these appeals. 3. Thus, the present appeals are also dismissed on account of low tax effect as quantified. Pending applications are also disposed of. VIBHU BAKHRU, J TEJAS KARIA, J MARCH 17, 2025 M This is a digitally signed order. The authenticity of the order can be re-verified from Delhi High Court Order Portal by scanning the QR code shown above. The Order is downloaded from the DHC Server on 20/03/2025 at 12:37:30

THE PRINCIPAL COMMISSIONER OF INCOME TAX - INTERNATIONAL TAXATION -1 vs. ARES DIVERSIFIED

What did the High Court hold?

What were the facts?

What were the issues?

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