Pr Commissioner Of Income Tax 1 v. Shreeji Traders

(406) ITXA-23.25.DOCX by LAXMIKANT GOPAL CHANDAN Date:

2025.11.13 10:35:50 +0530 LAXMIKANT GOPAL CHANDAN lgc

IN THE HIGH COURT OF JUDICATURE AT BOMBAY

ORDINARY ORIGINAL CIVIL JURISDICTION INCOME TAX APPEAL NO. 23 OF 2025 Pr. Commissioner of Income Tax 1 : Appellant

Versus

Shreeji Traders : Respondent ______________________________________________________ Mr Akhileshwar Sharma (Through V. C.), for the Appellant. ______________________________________________________

CORAM

M.S. Sonak & Advait M Sethna, JJ.

DATED:

11 November 2025 PC:- 1.

Heard Mr. Akhileshwar Sharma, the learned counsel for the Appellant.

2.

The tax effect in this Appeal is hardly Rs.24049/-. Mr. Sharma, however, submits that the case would fall within the exceptions carved out under the CBDT circulars. 3.

This is a case where even the ITAT has dismissed the Revenue's Appeal on the ground of low tax effect. The only question proposed relates to the interpretation of CBDT circulars and determination of whether the matter fell within the exceptions carved out therein.

4.

Considering the tax effect of only Rs.24049/-, we think that it would be appropriate if this issue is decided in some other suitable matter. There is no point in admitting this Appeal because in all probabilities the Respondent may not

(406) ITXA-23.25.DOCX even bother to attend to this matter given the low stakes involved.

5.

Therefore, by expressly keeping the point of law raised in this Appeal open, we decline to admit this Appeal on the ground of low tax effect.

6.

This Appeal is dismissed on the ground of low tax effect by keeping the questions of law raised therein expressly open to be decided in an appropriate case.

(Advait M Sethna, J) (M.S. Sonak, J)