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Judgment
These Revenue’s three appeals ITA No. 7574 – 7576/Del/2026 for assessment years 2013-14, 2014-15 & 2015-16, arise against the Commissioner of Income Tax (Appeals)/Addl./JCIT(A)-1, Mumbai [in short, the “CIT(A)”], orders dated 22.05.2026 involving proceedings under section 143(3) r.w.s. 147 of the Income-tax Act, 1961 (hereinafter referred to as ‘the Act’).
Heard both the parties. Case file perused.
It emerges at the outset that the Revenue's instant appeals involve tax effect of Rs.13,58,434/-, 3,50,238/-, 13,58,434/- respectively i.e. less than the minimum tax effect prescribed of Rs.60 lakhs in the CBDT latest Circular No. 9/2024, dated 17.09.2024.
Learned Departmental Representative is indeed very fair in not disputing the fact that the CBDT's foregoing tax effect circular has been made applicable with retrospective effect on all pending appeals as well. We thus reject the Revenue's instant three appeals for this precise reason subject to all just exceptions.
These Revenue's three appeals ITA Nos. 7574-7576/Del/2026 are dismissed in above terms. A copy of this common order be placed in the respective files.
