PCIT Vs Aaryan Rice Industries LLP (Chhattisgarh High Court)
The appeal was taken up for hearing, during which counsel for the appellant submitted that the Government of India, Ministry of Finance, had issued a new circular dated 17 September 2024 revising the monetary limits for filing income tax appeals by the Department before various judicial forums. Under the revised limits, the monetary threshold for filing appeals before the High Court has been increased to ₹2 crores. In the present case, the tax liability involved is less than ₹2 crores. Therefore, in view of the circular, it was submitted that the appeal may be finally disposed of.
The Court found the submission fair and reasonable. Relevant paragraphs of the circular were reproduced for reference. The circular revises monetary limits earlier prescribed under Circular No. 5/2024 dated 15 March 2024, setting the new limits at ₹60 lakh for the Income Tax Appellate Tribunal, ₹2 crores for the High Court, and ₹5 crores for the Supreme Court. It also clarifies that the limits apply to all cases, including those related to TDS/TCS, except where exceptions under paragraphs 3.1 and 3.2 of the earlier circular apply. The circular instructs that appeals should not be filed merely because the tax effect exceeds the limit but must be assessed on merits, with emphasis on reducing unnecessary litigation. It applies to all appeals and SLPs filed henceforth and to pending matters, which may be withdrawn accordingly. Issued under Section 268A of the Income-tax Act, 1961, the circular aims to streamline litigation management.
