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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

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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 Monetary Limit(Tax

matters effect in Rs.)

1. Before Income Tax Appellate 60 Lakhs

Tribunal

2. Before High Court 2 Crore

3. Before Supreme Court 5Crore

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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.”

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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/-

D s ii g g n it e a d l l by y (Parth Prateem Sahu) (Sachin Singh Rajput)

ALFIZA

ALFIZABAIG

BAIG Date:

2 1 0 4 2 :5 6 2. 0 :35 1. 15 Judge Judge

+0530

Alfiza