Pr Commissioner Of Income Tax 1 Thane v. Sanjay Co-Operative Credit Society Ltd Ay 2017-18

425-ITXA-523-2025 (OS).DOCX PALLAVI MAHENDRA WARGAONKAR Pallavi PALLAVI MAHENDRA WARGAONKAR Date: 2025.11.11 18:09:59 +0530

IN THE HIGH COURT OF JUDICATURE AT BOMBAY

ORDINARY ORIGINAL CIVIL JURISDICTION INCOME TAX APPEAL(IT) NO. 523 OF 2025 Pr Commissioner Of Income Tax 1 Thane ...Appellant

Versus

Sanjay Co-operative Credit Society Ltd.

A.Y. 2017-18

...Respondent

______________________________________________________ Mr. Akhileshwar Sharma (Thr. VC), a/w Ms. Shradha Worlikar for Appellant.

Ms. Shruti Kalyani for the Respondent.

______________________________________________________ CORAM : M.S. Sonak & Advait M. Sethna, JJ.

DATED : 6 November 2025 P.C.:- 1.

Mr. Sharma, learned counsel for the Appellant and Ms. Shruti Kalyani, learned counsel for the Respondent. 2.

Mr. Sharma points out that though tax effect in this Appeal is shown as less than Rs.2 Crores, the order challenged was made in exercise of Revisional Jurisdiction under Section 263 of the Income Tax Act. He submitted that such Appeal falls within the exceptions issued by the CBDT Circulars.

3.

The CBDT Circular of 15 March 2024, indeed provides that challenges to orders made in exercise of powers under Section 263 of the said Act would fall within the exceptions provided the tax effect is not quantifiable or involved. Here, the tax effect is quantified at less than Rs.2 Crores. Therefore, the

425-ITXA-523-2025 (OS).DOCX exception, would not be applicable.

4.

This Appeal is accordingly disposed of on the ground of low tax effect by keeping open the questions of law. No costs. (Advait M. Sethna, J) (M.S. Sonak, J.)