Disposed¶4

Pr Commissioner of Income Tax C2 v. Harshad S. Mehta

Bombay HC16 Oct 2025ITXA/249/2024

Case brief

AI extract

What is this about?

Low tax effect disposal of an income tax appeal before the High Court of Bombay (16 October 2025). Keywords: CBDT Circulars; Rs.2 Crore tax-effect threshold; cumulative tax effect across companion appeals rejected as a basis for pursuing the appeal; tax effect Rs.25,93,788/- (ITXA No.249 of 2024); companion appeal ITXA No.225 of 2024 with tax effect Rs.3.23 Crores unaffected, to be heard and decided on own merits; questions of law kept open; liberty; Pr Commissioner Of Income Tax C2 versus Harshad S. Mehta.

What did the court decide?

Appeal disposed of on the ground of low tax effect with the questions of law left open and with liberty; the Court clarified that the disposal would in no manner affect the hearing of ITXA No.225 of 2024. ¶4

Pr Commissioner of Income Tax C2 vs Harshad S. Mehta — Bombay HC (2025) — LawSathi Research

What the court decided

AI extract

Outcome

¶4

Issue for consideration

Whether the Revenue may proceed with ITXA No.249 of 2024 notwithstanding that its tax effect (Rs.25,93,788/-) falls below the Rs.2 Crores threshold under the CBDT Circulars, on the strength of the cumulative tax effect of this appeal together with companion appeal ITXA No.225 of 2024 (Rs.3.23 Crores). +1 more

¶1

Court's answer

Even on the cumulative-tax-effect basis advanced by Revenue counsel (combining the tax effects of ITXA No.249 of 2024 and ITXA No.225 of 2024 so as to exceed Rs.2 Crores), the Court held that it could not allow the Revenue to proceed with ITXA No.249 of 2024.

¶2

Ratio / Principle

The appeal stands disposed of on the ground of low tax effect, with the questions of law expressly kept open and with liberty.

¶4

Key takeaways

The disposal of this appeal will in no manner impact ITXA No.225 of 2024, which remains to be heard and decided on its own merits.ratio¶2

Detailed headnote1 paragraphs

Bombay High Court, Ordinary Original Civil Jurisdiction (M.S. Sonak & Advait M. Sethna, JJ.; dated 16 October 2025): Income Tax Appeal No. 249 of 2024 (referred to in the order as ITXA No.249 of 2024) by the Pr Commissioner Of Income Tax C2 against Harshad S. Mehta was disposed of solely on the ground of low tax effect. The tax effect of this appeal was Rs.25,93,788/-, below the Rs.2 Crores threshold under the CBDT Circulars within which appeals are not to be pursued by the Revenue. Revenue counsel (Ms. Smita Thakur) argued that the companion appeal ITXA No.225 of 2024 carried a tax effect of Rs.3.23 Crores, so the cumulative effect would exceed Rs.2 Crores; however, the Court held that, based on such cumulative effect, it could not allow the Revenue to proceed with ITXA No.249 of 2024. The appeal was disposed of with the questions of law expressly kept open and with liberty. The Court twice clarified that the disposal would, in no manner, impact ITXA No.225 of 2024, which is to be heard and decided on its own merits.

Pr Commissioner of Income Tax C2 v. Harshad S. Mehta

Case brief

What is this about?

What did the court decide?

Pr Commissioner of Income Tax C2 v. Harshad S. Mehta

Case brief

What is this about?

What did the court decide?

Why is it important?

What the court decided

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