ALLAHABAD HIGH COURT · SOURCE-REVIEWED PROCEDURAL ORDER
Commissioner of Income Tax-II and Another v. M/s Vardhman Resorts (P) Ltd.
Income Tax Appeal No. 414 of 2011 ·
Supplied court order; no reported citation stated
Appeal dismissed as not maintainable on the recorded low-tax-effect ground under Circular No.3/2018.
Division Bench · Bharati Sapru · Dinesh Kumar Singh
1. Facts of the case
The operative paragraph attributes the low-tax-effect statement to departmental counsel Shri Krishna Agrawal. The hearing paragraph instead names Shri Piyush Agrawal for Revenue and Shri Suyash Agrawal for the respondent. The supplied order states no assessment year or underlying assessment issue.
2. Discussion by the Hon’ble Court
The Court cited CBDT Circular No.3/2018 dated 11 July 2018 and concluded the appeal on the recorded monetary-limit ground. It did not analyse the assessment merits or discuss the circular’s exceptions.
3. Judicial decision
The appeal was dismissed as not maintainable on the stated low-tax-effect basis.
4. Outcome / in whose favour
Revenue’s appeal ended by procedural dismissal. The supplied order neither resolves a substantive tax question nor establishes that the underlying assessment position is correct on its merits.
5. AKHB REVIEW POINT
Keep the actual party, docket and date distinct from other formulaic low-tax-effect disposals. The 2018 circular’s historical threshold and exceptions are not a current-law clearance. A monetary-limit dismissal is not a substantive merits precedent.
Source and verification
Complete supplied one-page order read and visually inspected. Original SHA-256 independently reverified; full text matched the supplied review packet. No assessment year or PAN is stated. No later-proceedings or current-law clearance is claimed.
Source SHA-256: e04917fdae945755cc1ddcc510253f1993ab1a5f5aa1ccc14c4637e5661c7914
Only provisions expressly identified in this order are recorded. No substantive tax merits or current statutory equivalence is inferred.
Source checked 2026-10-18. Later proceedings, compliance and current precedential treatment have not been comprehensively verified.
AI disclosure and professional disclaimer
This AKHB research note was prepared with AI assistance from an identified primary report. Independent human review is not represented.
General legal and tax research only; not legal or tax advice. Verify the complete judgment, applicable statutory version and subsequent treatment before reliance. The AKHB REVIEW POINT is editorial analysis, not the Court’s holding. No current-law clearance is claimed.