ASSISTANT COMMISSIONER OF INCOME TAX, CIRCLE-1(1)(1), AHMEDABAD, AHMEDABAD vs. CONCORD BIOTECH LIMITED, AHMEDABAD

At the outset, it is informed by the Counsel for the assessee that the Tax Effect in both these Asst. Year 2018-19 is Rs.51,08,360/- and Asst. Year 2020-21 is Rs.53,89,164/- which is below Rs.60,00,000/- as prescribed by the CBDT Circular No. 09/2024 dated 17/09/2024 issued u/s. 268A of the Act. Since the assessment years passed for the above assessment years are regular assessment u/s. 143(3) of the Act, the above appeals filed by the Revenue are liable to be dismissed following C. No. 09/2024.

The Ld. CIT-DR appearing for the Revenue could not dispute the above facts. However he sought liberty be given to the Department to revive the above appeals in the event if the Tax Effect in the above appeals are higher.

Considering the above submissions of both parties, the above appeals filed by the Revenue are hereby dismissed following CBDT Circular No. 09/2024 dated 17/09/2024 with liberty to the Department to revive the appeals, in the event, if there is change in the disputed tax in the above appeals.

In the result, the appeals filed by the Revenue are hereby dismissed.

The first ground raised by the assessee in the above appeals are relating to Low Tax Effect of the above appeals. Since the Revenue appeals are dismissed following CBDT Circular No. 09/2024 dated 17/09/2024, the Cross Objection raised by the Assessee is hereby allowed.

In the result, Cross Objections filed by the Assessee are hereby allowed.