2026 (7) TMI 142

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....spondent: None.   PC:- 1. This Appeal is filed under Section 260-A of the Income Tax Act, 1961 ('IT Act' for short). It assails the Judgment and Order of the Income Tax Appellate Tribunal ('ITAT' for short) dated 2nd August 2018 ('Impugned Order' for short). 2. The Appeal is preferred on the following formulated substantial questions of law:- (i) Whether on the facts and cir....

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....s are unverifiable/non genuine/bogus, the same should have been disallowed in entirety, particularly in view of the ratio of the decision of the Hon'ble Gujarat High Court in Tax Appeal No.242 of 2003 dated 20.6.2016 in the case of N.K. Proteins Ltd against which the SLP was dismissed by the Hon'ble Apex Court. 3. Mr. Sharma, learned Counsel for the Appellant/Revenue has contended that though t....

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....st 2018 and not earlier. 5. Similar issue arose before the Co-ordinate Bench of this Court in Commissioner of Income Tax Vs. V.M. Salgaonkar and Brothers (P.) Ltd. (2024)169 taxmann.com 597 (Bombay). On analysing Circulars i.e. 5 of 2024 and 9 of 2024 issued by CBDT, the Co-ordinate Bench held that the enhanced monetary limits would apply to pending Appeals but when it comes to exceptions speci....