PRINCIPAL COMMISSIONER INCOME TAX, SURAT 2versusM/S SILVER ENTERPRISE
- Disposal
- 46-ANY OTHER MODE @ FH
Holding
The appeals are not maintainable and are disposed of on the ground of low tax effect as per Circular No. 9 of 2024.
Summary
The Principal Commissioner of Income Tax, Surat-1 appealed against Ms. Jashuben Rameshbhai Patel in multiple tax appeal matters. The appellants' senior standing counsel, Mr. Karan Sanghani, argued that the tax effect in each appeal was less than Rs.2 crores, invoking Circular No. 9 of 2024 which bars maintenance of appeals with such low tax impact. The Court examined the applicability of the circular and found the contention persuasive. Consequently, the Court disposed of all the listed tax appeals on the ground of low tax effect, granting liberty to revive the appeals if any difficulty arises. The order was signed by Justices A.S. Supehia and Pranav Trivedi.
Issues considered
- What is the applicability of Circular No. 9 of 2024 regarding the maintainability of tax appeals where the tax effect is less than Rs.2 crores?
Subjects
Judgment
C/TAXAP/472/2019 ORDER DATED: 13/01/2026
IN THE HIGH COURT OF GUJARAT AT AHMEDABAD
R/TAX APPEAL NO. 472 of 2019
With
R/TAX APPEAL NO. 487 of 2019
With
R/TAX APPEAL NO. 501 of 2019
With
R/TAX APPEAL NO. 502 of 2019
With
R/TAX APPEAL NO. 516 of 2019
With
R/TAX APPEAL NO. 519 of 2019
With
R/TAX APPEAL NO. 522 of 2019
With
R/TAX APPEAL NO. 533 of 2019
With
R/TAX APPEAL NO. 570 of 2019
==========================================================
PRINCIPAL COMMISSIONER INCOME TAX,SURAT-1
Versus
SMT.JASHUBEN RAMESHBHAI PATEL
==========================================================
Appearance:
MRS KALPANA K RAVAL(1046) for the Appellant(s) No. 1
MS VAIBHAVI K PARIKH(3238) for the Opponent(s) No. 1
==========================================================
CORAM:HONOURABLE MR. JUSTICE A.S. SUPEHIA
and
HONOURABLE MR. JUSTICE PRANAV TRIVEDI
Date : 13/01/2026
COMMON ORAL ORDER
(PER : HONOURABLE MR. JUSTICE A.S. SUPEHIA)
1. Learned Senior Standing Counsel Mr.Karan
Sanghani has submitted that he will be replacing
learned Senior Standing Counsel Mrs.Kalpana
Raval. Registry to accept his appearance note, as
and when it is filed.
2. Learned Senior Standing Counsel Mr.Sanghani
for the appellants has submitted that the tax
effect in the present appeals are less than Rs.2
Page 1 of 2
C/TAXAP/472/2019 ORDER DATED: 13/01/2026
crores and as per the Circular No.9 of 2024 dated
17.09.2024, the same would not be maintainable.
3. In view of the above statement, the Tax
Appeals are hereby disposed of on the ground of
low tax effect with a liberty to revive in case
of difficulty.
Registry to place a copy of this order in the
connected matter(s).
Sd/-
(A. S. SUPEHIA, J)
Sd/-
(PRANAV TRIVEDI, J)
NVMEWADA/S-9,15,21,23,29
Original copy of this order has been signed by the Hon'ble Judges.
Digitally signed by: NEHABEN VINODBHAI MEWADA(HC01571), PRIVATE SECRETARY, at High Court of Gujarat on 13/01/2026 15:08:29
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