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Income Tax Appellate Tribunal - Agra

Dcit Circle-2(1)(1), Agra vs Madhusudan Motors P Ltd, Agra on 3 July, 2019

                  In the Income-Tax Appellate Tribunal,
                             Agra Bench, Agra

     Before :     Shri Laliet Kumar, Judicial Member And
                  Dr. Mitha Lal Meena, Accountant Member

                   ITA Nos. 243, 244 & 245/Agr/2018
             Assessment Years: 2012-13, 2013-14 & 2014-15

        DCIT, Circle 2(1)(1),   vs.    M/s. Madhusudan Motors (P) Ltd.
        Agra.                         B-5, Lawyers Colony, Bye Pass Road,
                                      Agra. (PAN: AAACCM7645N)
        (Appellant)                   (Respondent)

             Appellant by       Shri Rajesh Malhotra, C.A.
             Respondent by      Shri Waseem Arshad, Sr. DR

                  Date of Hearing                   03.07.2019
                  Date of Pronouncement             03.07.2019


                                       ORDER

Per Bench:

These appeals are filed by the Revenue raising the following common grounds :
"1. That the Learned CIT(A) has erred in law and on facts in deleting the addition of Rs.38,37,000/- made by AO on account of disallowance u/s. 36(1)(iii) of the Act without appreciating the fact that the assessee utilized interest bearing funds to make interest free advances to related persons/mutual concerns without any business requirement.
2. That the order of Ld. Commissioner of Income Tax (Appeals) being erroneous in law and on facts deserves to be quashed and that of the Assessing Officer deserves to be restored."

2. From the perusal of the grounds of appeal, it is clear that the tax effect involved in each of these appeals is below the limit of Rs.20 Lakhs, prescribed by ITA Nos. 243, 244 & 245/Agr/2018 2 CBDT Circular No. 3/2018, dated 11th July, 2018, which is applicable even to the pending appeals. Thus, going by the prescription of Circular No. 3/2018, dated 11th July, 2018, we are of the view that the Revenue should have either not filed the instant appeals before the Tribunal or withdrawn the same, as the tax effect in these appeals is admittedly less than the prescribed limit, i.e., Rs. 20,00,000/-. Accordingly, we dismiss the appeals filed by the Revenue as non-maintainable.

3. In the result, the appeals of the Revenue are dismissed.

Order pronounced in the open court.

                 Sd/-                                           Sd/-
         (Dr. Mitha Lal Meena)                         (Laliet Kumar)
          Accountant Member                           Judicial member

Dated:
*aks*
Copy of order forwarded to:
(1)     The appellant                  (2)   The respondent
(3)     Commissioner                   (4)   CIT(A)
(5)     Departmental Representative    (6)   Guard File
                                                                                           By order

                                                                              Assistant Registrar
                                                                   Income Tax Appellate Tribunal
                                                                               Agra Bench, Agra