PCIT Vs Pratap Technocrats Private Limited (Rajasthan High Court)
The Rajasthan High Court dismissed the appeal filed by the Principal Commissioner of Income Tax (PCIT) against Pratap Technocrats Private Limited under Section 260A of the Income Tax Act. The dispute originated when PCIT challenged the deduction of ₹3.01 crore under Section 80JJAA, which the assessee had claimed for the Assessment Year 2018-19. The PCIT argued that the deduction should be disallowed since Form 10DA was not submitted with the income tax return. However, the Income Tax Appellate Tribunal (ITAT) had earlier ruled in favor of the assessee, accepting the deduction. The High Court upheld the ITAT’s decision, citing the Central Board of Direct Taxes (CBDT) Circular 9 of 2024, which states that appeals are not maintainable if the tax demand is less than ₹2 crore. Since the tax effect in this case was estimated to be around ₹1 crore, the court dismissed the appeal. The substantial legal question was left open for future consideration.
Assessee was represented by Sh. Sidharth Ranka, Adv.
FULL TEXT OF THE JUDGMENT/ORDER OF RAJASTHAN HIGH COURT
1. This appeal under Section 260A is filed against the order dated 07.2023 passed by learned Income Tax Appellate Tribunal, Jaipur (for short ‘Tribunal’).
