PCIT Vs Kamal Rameshbhai Doshi (Bombay High Court)
In the case Pr. Commissioner of Income Tax-27 vs. Kamal Rameshbhai Doshi (Income Tax Appeal No. 814 of 2019, Bombay High Court, 24th December 2025), the Bombay High Court disposed of the Revenue’s appeal on the grounds of low tax effect. The disputed claim in the appeal was valued at Rs. 29,84,148, which falls below the monetary threshold specified in CBDT Circular No. 9 of 2024. The Revenue argued that the case should be considered under Clause 10(e) of the amendment to Circular No. 3 of 2018, which allows appeals to proceed regardless of tax effect if additions are based on information from external sources such as law enforcement agencies.
Upon inquiry, the Revenue’s counsel confirmed that the assessment order had been passed independently by the Assessing Officer and was not based on any information received from external agencies. Consequently, the Court found that the exception cited by the Revenue did not prima facie apply. Since the tax effect was below the prescribed monetary limits and the case did not meet any exception criteria, the Court disposed of the appeal in favor of the assessee.
The Court granted the Revenue liberty to revive the appeal if it is later established that the case falls within any applicable exceptions. Any such revival would be decided on its merits and after hearing all parties. The order was formally issued and digitally signed for official use, ensuring compliance with procedural requirements.
