ALLAHABAD HIGH COURT · SOURCE-REVIEWED PROCEDURAL ORDER
Commissioner of Income Tax (TDS) and another v. State Bank of India
Income Tax Appeal Defective No. 13 of 2023 ·
Supplied court order; no reported citation stated
Exemption Application No. 1 of 2023 was allowed, exempting filing of the certified copy. The appeal was dismissed.
Division Bench · Pritinker Diwaker (Acting Chief Justice) · Saumitra Dayal Singh
1. Facts of the case
Revenue pressed a question of law but acknowledged, on the Court’s query, that the tax effect was below Rs. 1,00,000. A certified copy of the common Tribunal order had been annexed to Appeal No. 11 of 2023.
2. Discussion by the Hon’ble Court
The Court recorded the Rs. 1 crore monetary limit in CBDT Circular No. 17/2019 dated 8 August 2019 and also found the tax effect too small to warrant interference under Section 260A.
3. Judicial decision
Exemption Application No. 1 of 2023 was allowed, exempting filing of the certified copy. The appeal was dismissed.
4. Outcome / in whose favour
Revenue’s appeal ended on the recorded monetary-limit and small-tax-effect grounds, without deciding the substantive question of law.
5. AKHB REVIEW POINT
Distinguish the admitted tax effect below Rs. 1 lakh from the Rs. 1 crore circular limit quoted in this 2023 order; neither is a current-law clearance. Defective Appeal No. 13 and regular Appeal No. 11 of 2023 remain distinct. The exemption concerns the certified copy, not exemption from tax.
Source and verification
Complete supplied 1-page original read and visually inspected; original PDF bytes verified by SHA-256. Only source-identified provisions and assessment years are recorded. No PAN is stated. Subsequent treatment and current law have not been cleared.
Source SHA-256: 0a06dad2b43aed01d17bf40106a83183a6b9a88658d0cbc34ccce7193fa7520f
Only source-identified provisions are recorded. No current monetary threshold, current statutory equivalence or 2025 Act applicability is inferred.
Source checked 2026-10-20. Subsequent proceedings 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.