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Judgment
Per Satbeer Singh Godara, Judicial Member:
This Revenue’s appeal for Assessment Year 19 99-2000, arises against the CIT(A)-31 , Delhi’s DIN & order No. ITBA/APL/S/250/2024-25/1070337193(1) dated 13.11.2024, in proceedings u/s 158BC r.w.s. 254 of the Income Tax Act, 1961 (in short “the Act”).
Heard both the parties at length. Case file perused.
Coming to the Revenue’s sole substantive ground seeking to revive the Assessing Officer ’s action making the assessee’s cash expenditure payments disallowance of Rs.1,26,28,000/-which has been deleted in the CIT (A)’s lo wer appellate discussion, we note that the necessary tax thereon comes to be less than the minimum tax effect prescribed of Rs.60 lakhs as per 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 forego ing tax effect circular has been made applicable with retrospective effe ct on all pending appeals as well. We thus reject the Revenue's instant appeal for this precise reason subject to all just exceptions.
This Revenue's appeal is dismissed in above terms.