DCIT vs Satyam Educational Society

PER NAVEEN CHANDRA, ACCOUNTANT MEMBER :

The above captioned two appeals by the Revenue and Cross Objection by the assessee are preferred against order of the ld. Commissioner of Income Tax (Appeals) – NFAC, Delhi dated 17.09.2025 under section 154 r.w.s 250 of the Income Tax Act 1961 (herein after referred as ‘the Act’) arising from the assessment order dated 17.09.2025, passed by the Assessing Officer under Section 147 read with section 144B of the Income Tax Act, 1961 (‘the Act’) concerning Assessment Years 2018-19 & 2018-19.

Since the underlying facts are common in the cross objections of the assessee and Revenue and pertain to same assessee, they were heard together and are disposed of by this common order for the sake of convenience and brevity.

At the very outset, it was informed that the tax effect for the A.Y. 2018-19 is Rs.47,25,452/- and for the A.Y. 2019-20 is Rs.43,66,955/-, respectively. The tax effect for both the AYs are therefore below the prescribed limit as prescribed in the CBDT Circular No. 9/2024 dated 17.09.2024. Further, we are not apprised of any facts that these appeals fall under any exception clause of the said Circular. These appeals are accordingly, dismissed with liberty to the revenue to approach the Tribunal as per the provisions of law, should it feel that the tax effect is more than Rs. 60 lakhs.

As the appeals filed by the Revenue in ITA Nos.7902 & 7903/Del/2025 for A.Ys. 2018-19 & 2019-20, herein above have been dismissed on account of low tax effect, the cross objections filed by the assessee have become infructuous and likewise dismissed.

In the result, both the appeals filed by the Revenue are dismissed and cross objections filed by the assessee is dismissed.