Pr. Commissioner of Income Tax-7, Delhi v. Ujjawala Power Pvt. Ltd.

1. FACTS OF THE CASE

In ITA 3/2026, Revenue’s Senior Standing Counsel stated that the tax effect was below the limit in CBDT Circulars 5 and 9/2024. The caption also lists CM Applications 434, 435 and 436/2026. No underlying assessment facts or tax-effect figure are supplied.

Source: Caption and paragraph 1; PDF p.1

2. DISCUSSION BY THE COURT

The Court accepted the monetary-limit basis put forward by Revenue and dismissed the appeal in light of the circulars. No substantive tax issue or circular exception was examined.

Source: Paragraphs 1–2; PDF p.1

3. JUDICIAL DECISION

The appeal was dismissed in light of the cited CBDT circulars.

Source: Paragraph 2; PDF p.1

4. OUTCOME

Revenue’s challenge ended on the stated low-tax-effect ground. This order does not decide the underlying tax merits or quantify relief.

Source: Paragraphs 1–2; PDF p.1

5. Expert Comments

AKHB editorial analysis, distinct from the Court’s findings.

Revenue’s submission defines the reason for dismissal

The decisive fact recorded is Revenue’s own statement that the appeal falls below the circular limits. No taxpayer merits argument appears. The result therefore supports the procedural proposition that this particular appeal was dismissed under the litigation policy, not that a tax claim was independently adjudicated as correct.

Source: PDF p.1

The missing assessment detail is a real limit on comparison

The order gives neither the assessment year nor the numerical tax effect. Those omissions prevent using it to reconstruct a tax computation or identify a specific statutory controversy. Comparing another appeal requires its own facts and the relevant circular terms; this source alone supplies neither.

Source: PDF p.1

Record only the operative relief actually stated

Although three applications appear in the caption, paragraph 2 expressly dismisses the appeal without spelling out separate application rulings. It contains no remand, payment direction or express revival liberty. Reporting that limited operative wording preserves the distinction between this order and other low-tax-effect disposals with additional clauses.

Source: PDF p.1