Pr Commissioner Of Income Tax 1 Pune v. Capgemini Technology Services India Ltd

by PALLAVI MAHENDRA WARGAONKAR Date:

2025.10.10 16:13:18 +0530 413-ITXA-911-2024.DOCX PALLAVI MAHENDRA WARGAONKAR Pallavi

IN THE HIGH COURT OF JUDICATURE AT BOMBAY

ORDINARY ORIGINAL CIVIL JURISDICTION INCOME TAX APPEAL (IT) NO.911 OF 2024 Pr. Commissioner of Income Tax 1 Pune ...Appellant

Versus

Capgemini Technology Services India Ltd.

...Respondent

WITH INCOME TAX APPEAL (IT) NO.915 OF 2024 Pr. Commissioner of Income Tax 1 Pune ...Appellant

Versus

Capgemini Technology Services India Ltd.

...Respondent

_________________________________________________________________ Mr. Arjun Gupta for Appellant.

Adv. Smit Shah for Respondent.

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

DATED : 8 October 2025 P.C.:- 1.

The Tax effect in both these Appeals is less than Rs.2 Crores. 2.

In terms of the CBDT Circular, these Appeals ought not to be pursued by the Revenue. However, Mr. Gupta, learned counsel for the Appellant reports no instructions.

3.

Accordingly, we dispose of both these Appeals by leaving the questions of law open. However, if the Appellants find that the tax effect is greater than Rs.2 Crores or the Appeals fall within the excepted categories,

413-ITXA-911-2024.DOCX the Appellants will have liberty to apply for restoration/revival. This is provided applications for restoration/revival are made within reasonable time i.e. on or before 31 January 2026.

4.

Both the Appeals are disposed of with liberty in the above terms. (Advait M. Sethna, J) (M. S. Sonak, J.)