On September 17, 2024, the Central Board of Direct Taxes ( CBDT ) issued Circular No. 09/2024, which revised the monetary limits for filing income tax appeals before the Income Tax Appellate Tribunal ( ITAT ), High Courts ( HCs ), and the Supreme Court ( SC ). The pending appeals below the new threshold will be withdrawn by the department.
The updated thresholds raise the limits to Rs 60 lakh for ITAT, Rs 2 crore for HCs, and Rs 5 crore for SC appeals or Special Leave Petitions ( SLPs ). This amendment supersedes the previous limits set under Circular No. 5/2024 dated March 15, 2024, which were Rs 50 lakh for ITAT, Rs 1 crore for HCs, and Rs 2 crore for SC appeals. The increase in limits aims to mitigate the number of appeals filed over relatively minor tax disputes, thereby reducing the overall litigation burden.
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The new monetary thresholds will apply to all tax appeals, including those involving Tax Deducted at Source ( TDS ) and Tax Collected at Source ( TCS ) under the Income-tax Act, 1961. However, exceptions remain as outlined in paragraphs 3.1 and 3.2 of the previous circular. In such exceptional cases, the decision to file an appeal will be based on the merits of the case, rather than strictly adhering to the monetary limits.
The CBDT has also stated that appeals should not be pursued solely based on exceeding the revised monetary limits. Officers are encouraged to adopt a merit-based approach when deciding on appeals, with the primary goal of minimising unnecessary litigation. This directive aims to ensure that resources are focused on more substantial cases that warrant judicial attention.
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These changes, effective from the date of issuance of the circular, apply not only to new appeals but also to cases already pending before the Supreme Court, High Courts, and Tribunals. In cases where the monetary threshold is not met, pending appeals may be withdrawn, allowing the judiciary to focus on more relevant tax disputes.
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