2025 (2) TMI 1318 - HC - Income Tax

Maintainability of appeal on low tax effect: Appeal declined under CBDT monetary thresholds where tax effect Rs.16.09 Lakhs

High Court declined to entertain a challenge where the tax effect amounted to Rs.16.09 lakhs, applying the monetary thresholds set out in the CBDT ... Maintainability of appeal before High court on low tax effect - monetary limits prescribed in CBDT circulars HELD THAT:- The tax effect in this case is Rs.16.09 Lakhs. This Appeal was instituted on 5 April 2018. Therefore, following our order in [2025 (2) TMI 835 - BOMBAY HIGH COURT] and the CBDT circular, we decline to entertain this Appeal. Appeal is declined entertainment and disposed of on the ground of tax effect. Issues: (i) Whether the High Court should entertain the Revenue's appeal where the tax effect is Rs.16.09 Lakhs in light of the Court's earlier order and the CBDT circular.Issue (i): Whether the High Court should entertain the Revenue's appeal where the tax effect is Rs.16.09 Lakhs in light of the Court's earlier order and the CBDT circular.Analysis: The Court noted the tax effect in the appeal and referred to its prior order dated 12 February 2025 and the CBDT circular as the governing framework for entertainability. The Court applied those authorities to the present appeal and concluded that, on that basis, the appeal does not meet the threshold for being entertained.Conclusion: The appeal is not entertained and is disposed of on the ground of tax effect; the appeal is dismissed.Final Conclusion: The High Court refused to entertain the Revenue's appeal under the applicable threshold rule and administrative guidance contained in the CBDT circular, resulting in dismissal of the appeal.Ratio Decidendi: Where an appeal fails to meet the tax-effect threshold established by the Court's prior order and the CBDT circular, the High Court may decline to entertain and dismiss the appeal on that ground.