DCIT Vs Shriram Pistons And Rings Ltd. (ITAT Delhi)
SEO Titles: ITAT Delhi Dismisses DCIT Appeal on Low Tax Effect, Consistency Principle
This document presents the Order of the Income Tax Appellate Tribunal (ITAT), Delhi, concerning two appeals filed by the Revenue (DCIT) against separate Orders of the Ld. CIT(A)/NFAC, Delhi, related to Assessment Years (AY) 2015-16 and 2020-21. The assessee in the case is Shriram Pistons And Rings Ltd.
Appeal for AY 2015-16
The Revenue’s appeal for AY 2015-16 (ITA No. 4123/Del/2024) challenged the Ld. CIT(A)’s decision to allow the assessee’s appeal. Specifically, the Revenue contested the deletion of two additions:
1. Rs. 1,58,16,785/- for expenditure on account of dies for new model development.
2. Rs. 13,92,819/- for expenditure on account of Productivity Maintenance.
At the outset, the Counsel for the assessee submitted that the tax effect involved in this appeal is Rs. 58,06,504/-, which is below the prescribed limit of Rs. 60 lacs for filing an appeal before the Tribunal, as stipulated in CBDT Circular No. 09/2024 dated 17.09.2024. The Ld. DR had no objection to this proposition. Consequently, the ITAT deemed it fit and proper to dismiss the appeal of the Revenue (ITA No. 4123/Del/2024) as not maintainable in light of the aforementioned CBDT Circular.
