Created byFuzzy Cloud

High Court of Gujarat

COMMISSIONER OF INCOME TAX-IIIversusNILESH K. PATEL

Disposal
47-DISPOSAL IN ANY OTHER MODE FH

Holding

Tax appeals where the tax effect is less than Rs. 2 crores are not maintainable under Circular No. 9 of 2024.

Summary

The Commissioner of Income Tax-II filed multiple tax appeals (Nos. 1027, 1028, 1116, 1993 of 2008) against Labh Construction & Industries Ltd. The appellant argued that the tax effect in each appeal was less than Rs. 2 crores. The learned Senior Standing Counsel relied on Circular No. 9 of 2024 dated 17‑09‑2024, which stipulates that appeals with a tax effect below Rs. 2 crores are not maintainable. The Court examined the contention and found no merit in proceeding with the appeals given the statutory threshold. Consequently, the Court disposed of all the appeals on the ground of low tax effect, granting liberty to revive the matters only if difficulty arises. The order was signed by Justices A.S. Supehia and Pranav Trivedi.

Issues considered

  • Whether tax appeals with a tax effect of less than Rs. 2 crores are maintainable under Circular No. 9 of 2024

Subjects

tax appealcircularlow tax effectincome taxjurisdictionappeal dismissal

Judgment

       C/TAXAP/1027/2008                                                         ORDER DATED: 26/11/2025




                IN THE HIGH COURT OF GUJARAT AT AHMEDABAD

                               R/TAX APPEAL NO. 1027 of 2008
                                          With
                               R/TAX APPEAL NO. 1028 of 2008
                                          With
                               R/TAX APPEAL NO. 1116 of 2008
                                          With
                               R/TAX APPEAL NO. 1993 of 2008
 ==========================================================
                           COMMISSIONER OF INCOME TAX-II
                                      Versus
                        LABH CONSTRUCTION & INDUSTRIESLTD
 ==========================================================
 Appearance:
 DEV D PATEL(8264) for the Appellant(s) No. 1
 MR MANISH J SHAH(1320) for the Opponent(s) No. 1
 ==========================================================
   CORAM:HONOURABLE MR. JUSTICE A.S. SUPEHIA
         and
         HONOURABLE MR. JUSTICE PRANAV TRIVEDI

                               Date : 26/11/2025
                             COMMON ORAL ORDER
                  (PER : HONOURABLE MR. JUSTICE A.S. SUPEHIA)

          Learned Senior Standing Counsel Mr.Patel for
 the        applicant(s)                     has        submitted                 that          the         tax
 effect in these appeals are less than Rs.2 crores
 and        as       per        the         Circular               No.9          of      2024          dated
 17.09.2024, the same would not be maintainable.

          In       view          of       the        above           statement,                 the         Tax
 Appeals are 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/13
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 27/11/2025 10:41:22




                                                   Page 1 of 1


Search Indian case law

Ask in plain English, not just keywords. 25,000 AI words free, no card.

Try "tax appeal"Sign in to search

For a digitally signed copy suitable for filing, refer to the court's own website. Only the court can issue one.