2025 (5) TMI 1420

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....dated 17.09.2024 read with CBDT Circular No. 05/2024 dated 15.03.2024." 2. The Assessee has also placed on record the computation of tax effect in the present case, which indicates that it is below the threshold limit of Rs. 2 crores as stipulated in Circular No. 5 of 2024 dated 15.03.2024 as modified by the Circular No. 9 of 2024 dated 17.09.2024 issued by Central Board of Direct Taxes [CBDT]. In terms of the said circular, the threshold tax limit for appealing before this court was stipulated as Rs. 2 crores. The Assessee has set out a tabular statement computing the tax effect in the present case as Rs. 1,71,19,532/-. Paragraph 5 of the present application that includes the said tabular statement is set out below: "5. That in the pre....

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....e CBDT's Circular: "5.1 For this purpose, 'tax effect' means the difference between the tax on the total income assessed and the tax that would have been chargeable had such total income been reduced by the amount of income in respect of the issues against which appeal is intended to be filed (hereinafter referred to as 'disputed issues'). Further, 'tax effect' shall be tax including applicable surcharge and cess. However, the tax will not include any interest thereon, except where chargeability of interest itself is in dispute. In case the chargeability of interest is the issue under dispute, the amount of interest shall be the tax effect. In cases where returned loss is reduced or assessed as income, the tax effect would include notiona....