$~7 & 8 * IN THE HIGH COURT OF DELHI AT NEW DELHI + ITA 84/2006 COMMISSIONER OF INCOME TAX DEL .....Appellant Through: Mr. Gaurav Gupta, SSC and Mr. Shivendra Singh, JSC. versus JYOTSNA SURI .....Respondent Through: Mr. Prakash Kumar and Ms. Rashmi Singh, Advocates. + ITA 180/2006 COMMISSIONER OF INCOME TAX DEL .....Appellant Through: Mr. Gaurav Gupta, SSC and Mr. Shivendra Singh, JSC. versus JYOTSNA SURI .....Respondent Through: Mr. Prakash Kumar and Ms. Rashmi Singh, Advocates. CORAM: HON'BLE MR. JUSTICE DINESH MEHTA HON'BLE MR. JUSTICE VINOD KUMAR O R D E R % 17.01.2026 1. On perusal of the record more particularly the order dated 24.01.2005 passed by the Income Tax Appellate Tribunal (ITAT) in appeals i.e. ITA No. 2180/Del/98 and ITA No. 3085/Del/99 filed by the Department before it, we find that total addition for the Assessment Year 1996-97 was Rs.25,00,000/- while for the Assessment Year 1994-95 was Rs.3,13,18,000/-. This is a digitally signed order. The authenticity of the order can be re-verified from Delhi High Court Order Portal by scanning the QR code shown above. The Order is downloaded from the DHC Server on 19/01/2026 at 12:29:32 2. Such being a position, even if maximum rate of tax (40%) prevailing at that point of time i.e. 1996-97 taken into consideration, total tax effect would not be more than Rs.75,00,000/- which is definitely below the limit prescribed in CBDT Circular No.5/2024 dated 15.03.2024 read with circular No. 9/2024 dated 17.09.2024. 3. In view of the aforesaid, the appeals are dismissed. DINESH MEHTA, J. VINOD KUMAR, J. JANUARY 17, 2026/MR This is a digitally signed order. The authenticity of the order can be re-verified from Delhi High Court Order Portal by scanning the QR code shown above. The Order is downloaded from the DHC Server on 19/01/2026 at 12:29:32