PCIT Vs Prompt Barter Private Limited (Calcutta High Court)
The Calcutta High Court dismissed the Revenue’s appeal concerning deletion of a Rs.2,73,00,000 addition as unexplained cash credit under Section 68 of the Income Tax Act, 1961, for AY 2012-13. The appeal had been admitted on 17 November 2025 on questions concerning the ITAT’s deletion of the addition and its direction to the Assessing Officer, with the Revenue relying on decisions including Principal Commissioner of Income Tax (Central)-I Vs. NRA Iron & Steel (P) Ltd. and PCIT (Central)-2, Kolkata Vs. M/s. BST Infratech Ltd. The Revenue submitted that the tax effect was Rs.88,57,485, below the prescribed monetary limit under CBDT Circular No.9/2024 dated 17 September 2024 and Circular No.5 of 2024 dated 15 March 2024, but claimed the matter fell within an exceptional category under paragraph 3.1(h) of Circular No.5 of 2024. The Court examined the application, assessment order, Commissioner of Income Tax (Appeals) order and ITAT order dated 11 October 2023. It found that the Revenue had not clearly specified which exceptional clause under paragraph 3.1(h) applied to the appeal. Since the tax effect was below Rs.2 crore, the Court declined to entertain the appeal and dismissed it along with connected application GA/2/2025.
