The Pr. Comm. of I.Tax-25 V. M/s Trans Conduct (India) 50-ITXA 2437.2018.doc IN THE HIGH COURT OF JUDICATURE AT BOMBAY ORDINARY ORIGINAL CIVIL JURISDICTION INCOME TAX APPEAL NO.2437 OF 2018 The Principal Commissioner of Income Tax - 25 …Appellant Versus M/s Trans Conduct (India) …Respondent ---------- Mr. Suresh Kumar for the Appellant. Mr. Rahul Hakani a/w Priyanka Singh for the Respondent. ---------- CORAM : R.I. CHAGLA AND FARHAN P. DUBASH, JJ. DATE : 04 DECEMBER, 2025 ORDER : 1. The Income Tax Appeal is in respect of the disputed claim valued at Rs.55,27,709/- and thus below the tax effect of Rs.2 crores as per the Central Board of Direct Taxes (CBDT) Circular dated 17th September 2024. 2. Mr. Suresh Kumar, learned Counsel appearing for the Appellant – Revenue has submitted that this Appeal is covered by the exceptions in Circulars dated 20th August 2018 and 15th March 2024. --------------------------------------------------------------------------------------------------------------------------------------------------------------------------------- Order dated December 5, 2025 KAVITA SUSHIL JADHAV Digitally signed by KAVITA SUSHIL JADHAV Date: 2025.12.05 13:39:53 +0530 The Pr. Comm. of I.Tax-25 V. M/s Trans Conduct (India) 50-ITXA 2437.2018.doc 3. It has been held by this Court in Pr. Commissioner of Income Tax-14, Mumbai Vs. Premier Industrial Corporation Limited Income Tax Appeal No. 2061 of 2018 along with companion Income Tax Appeal No. 2063 of 2018 that the exceptions in the Circular dated 20th August 2018 apply only prospectively i.e. from the date of introduction of such exceptions. However, the monetary limits prescribed by the Circulars apply to pending Appeals. 4. Considering that the present Income Tax Appeal has been filed prior to the Circular dated 20th August 2018 and subsequent Circular dated 15th March 2024, this Appeal is not covered by the exceptions in these Circulars. 5. The tax effect in the present Income Tax Appeal is below Rs.2 Crores as per Circular dated 17th September 2024. 6. The Income Tax Appeal No.2437 of 2018 is disposed of on the ground that the tax effect therein is below Rs.2 crores as per Circular dated 17th September 2024. There shall be no order as to costs. --------------------------------------------------------------------------------------------------------------------------------------------------------------------------------- Order dated December 5, 2025 The Pr. Comm. of I.Tax-25 V. M/s Trans Conduct (India) 50-ITXA 2437.2018.doc 7. In the event the tax effect as involved is not within the parameters of the Circular dated 17th September 2024, liberty to revive this appeal. [FARHAN P. DUBASH, J.] [R.I. CHAGLA, J.] Kavita S.J. 50-ITXA 2437.2018.doc --------------------------------------------------------------------------------------------------------------------------------------------------------------------------------- Order dated December 5, 2025