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2026 DAILYLAW 18824 (CHH)

DEPUTY COMMISSIONER INCOME TAX OFFICER 1(1) v. M/S SHANNO BUSINESS INDIA PVT. LTD.

TAXC/25/2025 · 2026-05-13

Shri Parth Prateem Sahu, Shri Sachin Singh Rajput

Special Leave Petitionbody2026

Judgment text

Extracted from the PDF above. The PDF is authoritative.

1 2026:CGHC:22832-DB NAFR HIGH COURT OF CHHATTISGARH AT BILASPUR TAXC No. 25 of 2025 Deputy Commissioner Income Tax Officer 1(1) Bhilai (C.G.). ... Appellant versus M/s Shanno Business India Pvt. Ltd. 402, 3rd Floor, Rajiv Gandhi Complex Kutchery Chowk, Raipur Chhattisgarh, Pan - Aaics6905k ... Respondent For Applicant : Mr. Ajay Kumrani, Advocate For Respondent : None Division Bench Hon'ble Shri Justice Parth Prateem Sahu & Hon’ble Shri Justice Sachin Singh Rajput Judgment On Board 14.05.2026 Parth Prateem Sahu, J 1. When the case is taken up for hearing, learned counsel for appellant would submit that the Government of India, Ministry of Finance has issued a new circular dated 17.09.2024, in which monetary limits for filing Income Tax Appeals by the department before the High Court has 2 been enhanced to Rs. 2 crores, whereas in the present case the tax liability of assess is less then Rs. 2 crores. Therefore, in light of aforesaid circular dated 17.09.2024, the present appeal may be disposed of finally. 2. The said prayer appears to be fair and reasonable. 3. For ready reference, relevant paragraphs of said circular dated 17.09.2024 is quoted herein below: “1. Reference is invited to Circular No. 5/2024 (F.No. 279/Misc. 142/2007- ITJ (Pt)) dated 15.03.2024 of Central Board of Direct Taxes (the Board) vide which monetary limits for filing of income tax appeals by the Department before Income Tax Appellate Tribunal, High Courts and SLP/appeals before Supreme Court have been specified. Further, exceptions to the monetary limits were also specified vide paras 3.1 and 3.2 of the said circular. 2. As a step towards management of litigation, it has been decided by the Board of revise the monetary limits for filing of appeals in Income-tax cases as stated in Para 4.1 of the aforementioned circular as follows:- S.No. Appeals/SLPs in Income-Tax matters Monetary Limit(Tax effect in Rs.) 1. Before Income Tax Appellate Tribunal 60 Lakhs 2. Before High Court 2 Crore 3. Before Supreme Court 5Crore 3 3. Monetary limits given in paragraph 2 above with regard to filing appeal/SLP shall be applicable to all cases including those relating to TDS/TCS under the Income tax Act, 1961 with exceptions as per paras 3.1 and 3.2 of Circular No. 5/2024 dated 15.03.2024, where the decision to appeal/file SLP shall be taken on merits, without regard to the tax effect and the monetary limits. 4. It is clarified that an appeal should not be filed merely because the tax effect in a case exceeds the monetary limits prescribed above. Filing of appeal in such cases is to be decide don merits of the case. The officers concerned shall keep in mind the overall objective of reducing unnecessary litigation and providing certainly to taxpayers on their Income-tax assessments while taking a decision regarding filing an appeal. 5. The modification shall come into effect from the date of issue of this Circular. This Circular will apply to SLPs/appeals to be filed henceforth in SC/Hcs/Tribunal. It shall also apply to the SLPs/appeals pending before Supreme Court/High Courts/Tribunal, which may accordingly be withdrawn. 6. The above may be brought to the notice of all concerned. 7. This issue under Section 268A of the Income-Tax Act, 1961. 8. Hindi Version will follow.” 4 4. In view of the submission made by learned counsel for the appellant that, in the instant case the tax liability involved is less then the monetary limit fixed i.e. Rs. 2 Crores, hence the present tax case is disposed of in light of circular issued on 17.09.2024. Certified copy as per rules. Sd/- Sd/- (Parth Prateem Sahu) (Sachin Singh Rajput) Judge Judge Alfiza ALFIZA BAIG Digitally signed by ALFIZA BAIG Date: 2026.05.15 14:52:31 +0530