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Income Tax Appellate Tribunal - Delhi

Hcl Comnet Ltd., New Delhi vs Department Of Income Tax on 8 February, 2016

                    IN THE INCOME TAX APPELLATE TRIBUNAL
                      DELHI BENCH: 'A' NEW DELHI
            BEFORE SHRI S.V. MEHROTRA, ACCOUNTANT MEMBER
                                   AND
                MS. SUCHITRA KAMBLE, JUDICIAL MEMBER
                   I.T.A .No.-4907/DEL/2015 A.Y 2007-08
     DCIT                                vs  HCL Comnet Ltd.,
     Circle 11(1)                            806, Siddharth 96,
     New Delhi                               Nehru Place,
                                             New Delhi - 110 019
     (APPELLANT)                             AAACH9667H
                                             (RESPONDENT)


             Appellant by     Sh. Ravi Jain, CIT DR
             Respondent by    None

                     Date of Hearing       08.02.2016
                  Date of Pronouncement
                                          08.02.2016

                   ORDER
PER SUCHITRA KAMBLE, JM

This appeal is filed by the revenue against the order dated 26.05.2015 passed by CIT(A)-4, New Delhi.

2. The Ld. DR submitted that the tax effect involved in the present appeal is less than 10,00,000/-.

3. CBDT Circular No. F. No. 279/ Misc.142/207 ITJ(Pt) dated 10th December, 2015, in Para 3, 7 and 10 reads as under:

3. Henceforth, appeals/SLPs shall not be filed in cases where the tax effect does not exceed the monetary limits given hereunder:
S No. Appeals in Income-tax matters Monetary Limit (in Rs) 1 Before Appellate Tribunal 10,00,000/- 2 Before High Court 20,00,000/-
3 Before Supreme Court 25,00,000/-

.........

7. In the past, a number of instances have come to the notice of the Board, whereby an assessee has claimed relief from the Tribunal or the Court only on the ground that the Department has implicitly accepted the decision of the Tribunal or Court in the case of the assessee for any other assessment year or in the case of any other assessee for the same or any other assessment year, by not filing an appeal on the same disputed issues. The Departmental representative/counsels must make every effort to bring to the notice of the Tribunal or the Court that the appeal in such cases was not filed or not admitted only for the reason of the tax effect being less that the specified monetary limit and, therefore, no inference should be drawn that the decisions rendered therein were acceptable to the Department. Accordingly, they should impress upon the Tribunal or the Court that such cases do not have any precedent value. a the evidence of not filing appeal due to this instruction may have to be produced in courts, the judicial folders in the office of CsIT must be maintained in a systemic manner for easy retrieval.

.......

10. This instruction will apply retrospectively to pending appeals and appeals to be filed henceforth in High Courts/Tribunals. Pending appeals below the specified tax limits in para 3 above may be withdrawn/ not pressed. Appeals before the Supreme Court will be governed by the instructions on this subject, operative at the time when such appeal was filed."

4. Thus, this being a pending appeal is covered by the CBDT Circular No. F. No. 279/ Misc.142/207 ITJ(Pt) dated 10th December, 2015. The Ld. DR submitted that this appeal is withdrawn. He however, submitted that this should not be taken as precedence.

5. Considering the submissions of both the parties, the Revenue's appeal is dismissed as withdrawn by the Revenue. However, this withdrawal of Revenue's appeal will not hold as precedence in subsequent proceedings.

6. In result, the appeal is dismissed as withdrawn by the Revenue.

The order is pronounced in the open court on 8th of February 2016.

         Sd/-                                                   Sd/-

(S. V. MEHROTRA)                                         (SUCHITRA KAMBLE)
ACCOUNTANT MEMBER                                         JUDICIAL MEMBER

Dated:        08/02/2016

*R. Naheed*
 Copy forwarded to:

1.                          Appellant
2.                          Respondent
3.                          CIT
4.                          CIT(Appeals)
5.                          DR: ITAT                     ASSISTANT REGISTRAR
                                                           ITAT NEW DELHI



                                                Date

1.    Draft dictated on                                    PS
                                              08.02.2016

2.    Draft placed before author              08.02.2016 PS

3.    Draft proposed & placed before           .02.2016    JM/AM
      the second member

4.    Draft  discussed/approved         by     .02.2016    JM/AM
      Second Member.

5.    Approved   Draft    comes    to   the   .02.2016     PS/PS
      Sr.PS/PS

6.    Kept for pronouncement on                .02.2016    PS

7.    File sent to the Bench Clerk                         PS
                                              09.02.2016

8. Date on which file goes to the AR

9. Date on which file goes to the Head Clerk.

10. Date of dispatch of Order.