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2025 DAILYLAW 76935 (BOM)

PR.COMMISSIONER OF INCOME TAX-13,MUMBAI v. VARDHAMAN REMEDIES PVT.LTD

ITXA/2655/2018 · 2025-12-04

Shri Farhan Parvez Dubash, Shri R I Chagla

body2025

Judgment text

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10-itxa-2655-2018.doc The Pr. Comm of IT – 13, Mumbai Vs. Vardhaman Remedies P. Ltd. IN THE HIGH COURT OF JUDICATURE AT BOMBAY ORDINARY ORIGINAL CIVIL JURISDICTION INCOME TAX APPEAL NO.2655 OF 2018 The Pr. Commissioner of Income Tax – 13, Mumbai …Appellant Versus Vardhaman Remedies Pvt. Ltd. …Respondent ---------- Mr. Akhileshwar Sharma, Thru V.C. for the Appellant. ---------- CORAM : R.I. CHAGLA AND FARHAN P. DUBASH, JJ. DATE : 4TH DECEMBER, 2025 ORDER : 1. The Income Tax Appeal is in respect of the disputed claim valued at Rs.21,99,790/- 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. Akhileshwar Sharma, learned Counsel appearing for ------------------------------------------------- Order dated December 4, 2025 JITENDRA SHANKAR NIJASURE Digitally signed by JITENDRA SHANKAR NIJASURE Date: 2025.12.06 12:03:50 +0530 10-itxa-2655-2018.doc The Pr. Comm of IT – 13, Mumbai Vs. Vardhaman Remedies P. Ltd. the Appellant – Revenue has submitted that this Appeal is covered by the exceptions in Circulars dated 20th August 2018 and 15th March 2024. 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 exception. 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. ------------------------------------------------- Order dated December 4, 2025 10-itxa-2655-2018.doc The Pr. Comm of IT – 13, Mumbai Vs. Vardhaman Remedies P. Ltd. 6. The Income Tax Appeal No.2655 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. 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.] 10-itxa-2655-2018.doc jsn. ------------------------------------------------- Order dated December 4, 2025