2025 (3) TMI 1437 - HC - Income Tax

Maintainability of appeal before High Court on low tax effect - appellant would submit that the Government of India Ministry of Finance has issued a new circular dated 17.09.2024 in which monetary limits for filing Income Tax Appeals by the department before the High Court has been enhanced to Rs. 2 Crores whereas in the present case the tax liability of assess is less than Rs. 2 Crore HELD THAT - In view aforesaid submission of appellant where monetary limit (tax liability) in the present case is less than Rs. 2 Crores therefore in light of aforesaid circular (Para-5) dated 17/09/2024 the instant Tax Case stands disposed of.

Summary

**Judgment Summary: Chhattisgarh High Court****Case Overview:**The case was presided over by Hon'ble Shri Justice Sanjay K. Agrawal and Hon'ble Shri Justice Sanjay Kumar Jaiswal. The appellant was represented by Mr. Amit Chaudhari and Mr. Vijay Chawla, while there was no representation for the respondent.**Key Legal Issue:**The primary legal issue involved the applicability of a new circular issued by the Government of India, Ministry of Finance, which revised the monetary limits for filing Income Tax Appeals by the department before the High Court to Rs. 2 Crores.**Legal Reasoning:**1. **Circular Reference:** The court referenced Circular No. 5/2024, dated 15.03.2024, which specified the monetary limits for filing appeals in Income-tax matters, including appeals to the Income Tax Appellate Tribunal, High Courts, and the Supreme Court. The circular aimed to manage litigation by revising monetary thresholds: Rs. 60 Lakh for the Tribunal, Rs. 2 Crore for the High Court, and Rs. 5 Crore for the Supreme Court.2. **Application to Current Case:** The appellant's counsel argued that the tax liability in the present case was less than Rs. 2 Crores, thus falling below the threshold for filing an appeal to the High Court as per the new circular dated 17.09.2024.3. **Court's Decision:** The court found the appellant's submission to be "fair and reasonable" and, in light of the circular, decided to dispose of the appeal since the tax liability did not meet the revised monetary limit for High Court appeals.**Conclusion:**The court disposed of the tax case based on the revised monetary limits established by the circular, emphasizing the objective of reducing unnecessary litigation and providing certainty in tax assessments.