CBDT Circular on Monetary Limits Not applicable to DTAA Appeals

CIT (International Taxation)-2 Vs Perfetti Van Melle ICT B.V.(Panjab Haryana high court)

Punjab & Haryana High Court dismissed an appeal filed by the CIT (International Taxation)-2 against Perfetti Van Melle ICT B.V., ruling that CBDT Circular No. 9/2024, which sets monetary limits for filing appeals, does not apply to cases involving international taxation under Double Taxation Avoidance Agreements (DTAA). The Revenue argued that the appeal fell under an exception outlined in para 3.1 of Circular No. 5/2024, contending that the monetary limit restriction did not apply. However

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