Monetary limits prescribed in CBDT Circulars would apply to pending appeals as well; however, exceptions carved out by CBDT Circulars would apply only prospectively. Appeal filed by revenue on 21-5-2015; the exception relied upon by revenue as a justification for prosecuting said appeal was introduced vide Circular dated 15-3-2024, and said exception would have no application. Since the tax effect in the appeal was below the monetary limits as set out in CBDT Circular dated 17-9-2024, the appeal was to be disposed of. Followed, PCIT v. Premier Industrial Corporation Ltd (2025) 172 taxmann.com 289 (Bom) HC) Circular No. 9 of 2024, dated 17-9-2024 and Circular No. 5 of 2024, dated 15-3-2024.
CIT (IT) v. Bennet Coleman & Co. Ltd. (2025) 307 Taxman 62 (Bom.)(HC)
S. 268A: Appeal-Instructions-Monetary limits prescribed in CBDT Circulars would apply to pending appeals-Exceptions carved out by CBDT Circulars would apply only prospectively-Appeal of revenue dismissed.[S. 260A]
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