Revenue Cannot File Appeals Before HC If Income Tax Effect Is Below ₹2 Crores; CBDT Circular Applies Retrospectively

PCIT Vs IPL Loan Trust (Bombay High Court)

The Bombay High Court addressed several appeals, including PCIT vs. IPL Loan Trust, which were initially slated for withdrawal due to CBDT Circulars 05/2024 and 09/2024. These circulars pertain to cases where the tax effect is less than Rs. 2 crores. The Revenue argued that the appeals fell within certain exceptions outlined in Circular No. 05/2024, specifically paragraph 3.1(h), which concerns cases involving organized tax evasion. The Respondents countered, citing legal precedent, that the circulars have a dual application: retrospective

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